The short answer is no, and the useful answer is longer, because "no treaty" is where most write-ups stop and it is not where the question ends. Something does connect the two tax administrations. It is not a double taxation convention, it does less than people assume, and both governments have formally opted out of the part Canadians most often worry about.
This page sets out the whole instrument map, with the source for each line, so you can check it rather than take our word for it.
The three places you can check the answer
Canada's Department of Finance publishes the status of every Canadian tax treaty in three lists — in force, signed but not yet in force, and under negotiation. Montenegro appears on none of them. Croatia, Slovenia and Serbia all appear on the in-force list. The page was last updated on 21 July 2026.
Montenegro's Ministry of Finance keeps the mirror-image register: forty conventions, twenty-nine of them inherited from the Yugoslav-era states and eleven negotiated by Montenegro itself. Canada is in neither group, under any spelling.
The third check is the one worth doing, because the first two prove a negative by absence. Global Affairs Canada runs the Canada Treaty Information database, which lists Canadian bilateral treaties by partner state. Query Montenegro and it returns no treaties at all — not a tax convention, not a social security agreement, not an investment agreement. Query Serbia and the same database returns nine. So the empty result is not the database being thin; it is the record.
The Serbia trap
This is the specific way the question goes wrong, because Serbia is on Canada's treaty list and the two countries were one state until 2006.
The Canada–Serbia Income Tax Convention was signed on 27 April 2012 and entered into force on 31 October 2013. Montenegro declared independence on 3 June 2006. The convention was therefore negotiated and signed almost six years after the two states separated, with a Serbia that no longer included Montenegro. It never applied here and was never capable of applying here.
The gap widens when you look past tax. Canada and Serbia also have an Agreement on Social Security, in force since 1 December 2014, and an agreement on the promotion and protection of investments, in force since 27 April 2015. Montenegro has neither with Canada.
| Instrument | Canada–Serbia | Canada–Montenegro |
|---|---|---|
| Income tax convention | Signed 27 April 2012, in force 31 October 2013 (income and capital) | None |
| Social security agreement | In force 1 December 2014 | None |
| Investment promotion and protection | In force 27 April 2015 | None |
| Multilateral tax assistance convention | Party | Party |
There was never a Yugoslav tax convention to inherit
Montenegro inherited twenty-nine tax conventions, so the natural next question is whether a Canada–Yugoslavia convention exists somewhere in that pile, unclaimed. It does not, and this is provable rather than merely unfound.
Canada's treaty database keeps a separate Yugoslavia record, and it returns ten instruments — a 1988 film and video co-production agreement, a 1985 air transport agreement (terminated), a 1980 agreement on the protection of investments, a 1977 trade agreement, a 1967 exchange of notes waiving visa fees (terminated), a 1948 compensation agreement, a 1939 exchange of notes on legal proceedings, and older items back to an 1901 extradition treaty (terminated).
Note what that list includes: terminated treaties. The database is not a list of what survives; it is a record of what was concluded. And in the whole Yugoslav record there is no tax convention of any kind. Canada and Yugoslavia never had one, so no successor state inherited one.
The same point shows up on the Canadian side in a quieter way. Finance Canada's in-force page does carry superseded predecessors where they exist — under Czech Republic it still lists the Canada–Czechoslovakia Tax Convention signed on 30 August 1990. There is no Yugoslavia entry to list.
What does exist: one multilateral convention
Both countries are parties to the Convention on Mutual Administrative Assistance in Tax Matters, as amended by the 2010 Protocol. On Canada's own tax-information-exchange page it is the single entry under "Multilateral agreements in force". It is the instrument that actually links the two tax administrations.
The dates are not close together. Canada signed in 2004, deposited its instrument for the amended convention on 21 November 2013, and it entered into force for Canada on 1 March 2014. Montenegro acceded on 3 October 2019, deposited on 28 January 2020, and it entered into force for Montenegro on 1 May 2020.
What that convention does not do is relieve double taxation. It has no residence tie-breaker, no article allocating taxing rights over rental income or pensions, and no reduced withholding rates. It is an administrative-cooperation instrument: exchange of information, assistance in recovery, service of documents. Which makes the reservations the important part.
Both states opted out of collecting each other's tax debts
Parties to the Convention may file reservations under Article 30, and the depositary publishes every one of them. Read side by side, Canada's and Montenegro's are unusually symmetrical on the point that matters most.
Montenegro reserved under Article 30(1)(b) the right not to provide assistance in the recovery of any tax claim, or any administrative fine, for all taxes. Canada reserved under the same sub-paragraph, in almost the same words, that it will not provide assistance in the recovery of any tax claim or administrative fine for any tax under Articles 11 to 16.
So the convention that connects the two states does not lend either revenue authority the other's collection machinery. Neither will pursue the other's tax debt on its own territory.
Both also reserved under Article 30(1)(d) against assisting in the service of documents, with one asymmetry worth knowing: Canada's reservation expressly does not extend to service by mail under Article 17(3). Montenegro's carries no such carve-out.
Montenegro filed two further reservations — under Article 30(1)(a), declining assistance for tax categories outside its Annex A, and under Article 30(1)(c), declining assistance for tax claims that already existed when the convention entered into force for it.
Source: the depositary's register of reservations and declarations for the Convention on Mutual Administrative Assistance in Tax Matters, status as at 28 August 2026; Montenegro's instrument deposited 28 January 2020 and clarified by a note verbale of 17 February 2020, Canada's deposited 21 November 2013.
What Montenegro actually agreed to exchange
Each party lists the taxes it brings into the convention in Annex A, and the two lists are very different sizes.
Montenegro's Annex A contains two taxes: Personal Income Tax and Corporate Income Tax. That is the whole list. The real estate transfer tax you pay on a purchase, the annual property tax on the apartment, and VAT are not in it.
Canada's Annex A is considerably longer — taxes on income or profits including capital gains, and taxes on net wealth, imposed under the Income Tax Act and the Global Minimum Tax Act; the Value Added Tax under Part IX of the Excise Tax Act; and excise taxes under the Excise Tax Act and the Excise Act, 2001. Canada updated that list by note verbale on 26 January 2026, with effect from 1 May 2026.
Two Montenegrin declarations round out the picture, and neither is widely reported. Under Article 4(3), Montenegro declared that under its domestic law its authorities may inform its own resident or national before transmitting information about that person under Articles 5 and 7. Under Article 9(3), Montenegro gave notice that it will not, as a general rule, accept requests for representatives of another state to be present at tax examinations on its territory. Montenegro's competent authority for the convention is the Ministry of Finance; Canada's is the Minister of National Revenue.
The automatic layer: CRS
Separately from requests, both states have signed the Multilateral Competent Authority Agreement on the automatic exchange of financial account information. Canada signed on 2 June 2015, with first exchanges from September 2018. Montenegro signed on 3 March 2022, with first exchanges from September 2023.
One honest limit here. Signing that agreement does not by itself create an exchange relationship with any particular partner — relationships are activated bilaterally, and the OECD publishes the activated pairs in a separate list we were not able to retrieve on 28 August 2026. Treat "both have signed" as established and "Canada and Montenegro exchange automatically with each other" as the thing to confirm, not assume, before you rely on it either way.
Investment protection: read the record carefully
The 1980 Canada–Yugoslavia agreement on the protection of investments is still recorded as in force, and Canada's database returns it under Serbia. It does not return it under Montenegro, and Canada's newer investment agreement is with Serbia alone.
We are describing what the treaty record shows, not offering a view on state succession to investment treaties, which is a genuinely contested area. The practical point for a Canadian putting money into a Montenegrin company or a development is narrower and safe to state: do not assume an investment treaty stands behind you here. Whatever protection you have will come from the contract, the corporate structure and the arbitration clause you negotiate, not from a bilateral instrument the record does not attribute to Montenegro.
Documents: Canada joined the Apostille Convention on 11 January 2024
This one is recent enough that a lot of Canadian advice is still out of date.
Canada deposited its instrument of accession to the Hague Apostille Convention on 12 May 2023, and the Convention entered into force for Canada on 11 January 2024. Montenegro has been a party by succession with effect from 3 June 2006. Both being parties, a Canadian public document going to a Montenegrin notary or the cadastre needs a single apostille — the old consular legalisation chain is gone.
The practical trap is which authority issues it, because Canada designated six:
| Where the document was issued | Competent authority |
|---|---|
| Federal documents, and provinces without their own authority | Global Affairs Canada, Authentication Services Section (Ottawa) |
| British Columbia | Ministry of the Attorney General |
| Alberta | Ministry of Justice |
| Saskatchewan | Ministry of Justice and Attorney General |
| Ontario | Ministry of Public and Business Service Delivery and Procurement |
| Quebec | Minister of Justice |
Some Canadian missions abroad also offer the service within their consular district. Sending an Ontario document to Ottawa, or a federal document to a provincial office, is the most common way a completion date slips. The instrument that usually needs this treatment is the power of attorney, and its scope is where transactions actually fail — we set that out in our guide to the power of attorney for a Montenegrin purchase.
Entry: ninety days, on a passport
Canadians are listed in Article 1 of Montenegro's Visa Regime Regulation, which allows entry, transit and stay of up to 90 days with a valid passport and no visa. That is the ordinary visa-free position, not a concession with an expiry date attached: the changes taking effect on 1 November 2026 concern other articles of the same regulation, and we track them in our note on what changes in November 2026.
Two cautions. The regulation grants days; it does not override the Foreigners Act, and the statutory ninety-days-in-any-hundred-and-eighty ceiling is counted separately from any single entry — the counting mechanics are worked through in our entry-requirements analysis, which is written for American readers but explains the same articles. And a Canadian permanent resident who is not a Canadian citizen is in a different position entirely: Article 1 follows the passport, not the residence card.
The Canadian side we do not answer
We are Montenegrin counsel. We flag what follows you home; we do not compute it.
Three things come up in nearly every Canadian file, and each belongs with a Canadian adviser. Form T1135, the Foreign Income Verification Statement, is required where specified foreign property exceeds a $100,000 cost-amount threshold — and the CRA's own guidance is that specified foreign property excludes personal-use property, including a vacation property used primarily as a personal residence, with "primarily" meaning more than 50% and the question decided on the facts. On the CRA's own worked example, a condominium used exclusively as a vacation home is not reportable; the same condominium rented out for eight months with a reasonable expectation of profit is. So how you intend to use the Montenegrin apartment changes your Canadian filing position, and it is worth settling before completion rather than after.
The other two are departure tax on ceasing Canadian residence, and the determination of non-residence itself, which turns on Canadian rules about ties rather than on holding a Montenegrin residence permit. In the absence of a treaty there is no tie-breaker article to resolve a conflict between the two systems, which is the same structural gap Americans face here and which we set out at length in the American reporting guide.
Relief from double taxation, where it arises, will come from Canadian domestic law — the foreign tax credit exists independently of any treaty — rather than from a convention. That makes your Montenegrin tax receipts the whole evidentiary basis for the claim. Keep them.
What to send us
If you are at the stage where a listing, a reservation form or a draft contract exists, that is when a review is worth most. Send the draft contract, the cadastre extract for the unit, and one line about how you intend to hold it and where you are tax resident. We will tell you the Montenegrin position and flag, in writing, the questions that belong to your Canadian adviser so you can put them clearly rather than discovering them in April.
The wider treaty picture — which countries Montenegro does have conventions with, and which of them cover capital as well as income — is set out in our analysis of Montenegro's treaty network.
Write to us and tell us you are buying from Canada.
