Page 46 - Central and Eastern European Transfer Pricing Review

46 | CEE Transfer Pricing Review

Other recent Does the tax authority publish APA
developments data either in the form of an annual
report or through the disclosure of
Not applicable. data in public forums?
Not applicable.
Tax treaty/double tax
resolution Please provide some information
on how successful the APA program
What is the extent of the double tax is and whether there are any known
treaty network? diffculties?
Minimal. Not applicable.
If extensive, is the competent
authority effective in obtaining Language
double tax relief? In which language or languages
No experience. can documentation be fled?
Montenegrin.
When may a taxpayer submit an
adjustment to competent authority?
No formal rules.

May a taxpayer go to competent
authority before paying tax?
No formal rules.

Advance pricing
arrangements
What APA options are available,
if any?
No APAs or advance rulings of any kind
are available.

Is there a fling fee for APAs?
Not applicable.

KPMG in Montenegro

Igor Lončarević
Tel: +381 11 20 50 570
Email: iloncarevic@kpmg.com

As email addresses and phone numbers change
frequently, please email us at transferpricing@
kpmg.com if you are unable to contact us via the
information noted above.
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