Exchange of Information (EOI) for tax purposes is a key element of international tax cooperation and is essential for ensuring the correct allocation of taxing rights between countries and ensuring that countries can enforce their own tax laws. Montenegro has entered into Double Taxation Agreements (DTAs) containing provisions that provide for the exchange of information for tax purposes with other jurisdictions. Montenegro is a signatory to the Multilateral Convention on Mutual Administrative Assistance in Tax Matters (MAAC), which provides for a wide range of mutual administrative cooperation with other jurisdictions that are signatories. Given Montenegro's European Union accession status, Montenegro has also transposed into its domestic legal framework Council Directive 2011/16/EU of 15 February 2011 on administrative cooperation in the field of taxation and repealing Directive 77/799/EEC.

This Manual establishes operational guidelines applicable to the relevant tax framework, covering taxes within its scope as defined by the Instruction. For the avoidance of doubt, the scope of this Manual excludes value-added tax, customs duties, excise duties regulated by specific European Union legislation, and social security contributions. These exclusions are in line with paragraph 7 of the Instruction and ensure that the Manual is consistently applied within its intended substantive scope.

The different forms of exchange of information provided for by international legal instruments governing the exchange of information for tax purposes (EOI agreements) that Montenegro has concluded or will conclude include:

Exchange of Information on Request (EOIR): the exchange of information based on a request submitted by a jurisdiction in a specific case in accordance with a legal instrument concluded between that jurisdiction and Montenegro which allows for the exchange of information on request.

Spontaneous Exchange of Information (SEOI): the non-systematic communication, at any time and without prior request, of information relevant to another jurisdiction in accordance with a legal instrument concluded between that jurisdiction and Montenegro which allows for the spontaneous exchange of information.