Central Bank: Make a long-term assessment of the impact of the reduction of the PIO Fund contribution

The Central Bank issued an opinion on the Fiscal Strategy Proposal, in which it indicated that the reduction of contributions is risky

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Illustration, Photo: Luka Zeković
Illustration, Photo: Luka Zeković
Disclaimer: The translations are mostly done through AI translator and might not be 100% accurate.

The Central Bank (CBCG) proposes to supplement the fiscal strategy with a long-term assessment of the impact of the reduction of contributions for pension and disability insurance (PIO) on the burden of the employee and the employer. This measure systematically affects the income of PIO and pensions of employees, and it is necessary to simulate the amount of the pension, in a similar way as it was done at the salary level with a horizon of up to 20 years.

We also propose to make an assessment of the impact of these measures on the income and sustainability of PIO with a long-term horizon.

This is written, among other things, in the opinion of the CBCG on the Fiscal Strategy Proposal, which the Council of the Supreme Monetary Institution adopted yesterday.

"Reducing the burden on employers through allocation to the PIO Fund has positive sides, but it also brings with it potential fiscal risks. Reducing the contribution rate will increase the competitiveness of the economy, due to reduced labor costs, and have potential positive effects on reducing the outflow of labor abroad. This is important , in the context of the need to preserve human capital due to the increasingly certain entry of Montenegro into the EU. The reduction of contributions to the PIO can also reduce the informal employment, which the Fiscal Strategy provides for the period 2024-2027 it is desirable to look at the far-reaching consequences of the abolition of pension contributions," said the Central Bank, which is reproduced in full below

Assessment of the Fiscal Strategy

In addition to the legal obligation, the adoption of the Fiscal Strategy enables the systematic management of fiscal policy and the responsible management of public finances, through the implementation of measures and policies that are the result of a thorough analysis, which reduces or eliminates the scope for the adoption of ad hoc measures that may affect the sustainability of public finances. .

The strategy includes significant fiscal measures aimed at reducing the tax burden on labor, improving the competitiveness of the Montenegrin economy, reducing the gray economy, improving the standard of living, improving the investment environment, reforming the tax and customs administration, harmonizing the excise policy with European Union (EU) directives, maintaining fiscal parameters within the framework of the Maastricht criteria, which are important preconditions for dynamic economic growth in the medium term.

The Central Bank (CBCG) supports the decision in the Fiscal Strategy, which is also recognized in the Joint Conclusions of the Economic and Financial Dialogue between the European Union and Montenegro, and that a surplus is planned in the current budget, and that borrowing is exclusively carried out for capital projects. On the other hand, the level of public debt should not exceed 60% of GDP until 2026, which was also recognized in the agreed joint conclusions of May 2024.

The quantitative objectives of the Strategy, which predict an average amount of the capital budget of 3,9% of GDP for the period 2024-2027, also speak in support of the above. year, which recognizes the development component of fiscal policy measures, since the amount of the planned deficit is caused by the capital budget.

A budget deficit of 3,5% of GDP in 2025 to 3,3% of GDP in 2027 is foreseen. Projected level of public debt in the period 2024-2027. was planned at the level of 64% per year, and the net public debt averaged around 61,3% per year. The recommendation of the European Commission (EC) and the ECB is that the debt should be within the framework of the Maastricht criteria. For debt repayment in the period 2025-2027. 2 billion euros will be needed in 15 (829 million euros in 2025, 353 million euros in 2026 and 971,7 million euros in 2027). CBCG welcomes the plan defined in the Strategy that funds for servicing the public debt will be provided gradually, but even so, it is expected that future refinancing debts will be less favorable than the initial debts.

The strategy does not analyze the negative macroeconomic scenarios presented in the Program of Economic Reforms 2024-2026. (PER) through lower growth scenarios. The question arises, what if in the event of a negative macroeconomic shock (which is not foreseen by the Strategy, but is foreseen by PER) budget revenues do not increase in accordance with the projection. The Strategy lists key risks that could affect the achievement of growth projections and macroeconomic stability in the coming period, but does not include "stress scenarios", i.e. unexpected negative macroeconomic scenarios, a projected growth rate of 3,7% in the four-year analyzed period has already been given. Therefore, it is useful to include negative scenarios from PER in the analysis, regardless of the probability of their realization. We also point out the uncertainty of achieving the planned GDP growth rate of 4,8% in 2025, due to the possibility of a number of non-residents leaving, as well as due to the announced multi-month overhaul of the Pljevlja Thermal Power Plant.

The fiscal strategy also includes the economic Program for reducing the tax burden on wages and increasing the minimum wage (hereinafter referred to as the Program), whose key measures include:

reduction of contributions for pension and disability insurance at the expense of the employee from 15% to 10%;

- reduction of contributions for pension and disability insurance at the expense of the employer from 5,5% to 0%; increase in the minimum salary (up to the V level of education qualification, the minimum salary will be €600, while for the VI and higher level of education qualification, it will be €800).

In addition, an increase in pensions by 7-8% has been announced, if inflation is zero, and if it grows, a larger increase is expected. According to the fiscal strategy, it is planned that in the coming period pensions will be paid through the PIO Fund and that the pension system will be based on the first pillar, while the second pillar has been abandoned.

The growth of wages will lead to the growth of living standards and the reduction of inequality, which is one of the most important goals of economic policy. Nevertheless, the growth of minimum wages represents a financial challenge for a number of micro, small and medium enterprises, which are an important backbone of economic growth. It will be challenging for this category of companies to finance the proposed level of minimum wages, due to limited financial resources. Therefore, there is a risk of the gray economy growing, as high pressures to maintain that level of wages could force some businesses to operate informally, in order to reduce costs. Also, companies could resort to concluding part-time or part-time contracts, as well as engaging employees through employment agencies, bypassing the minimum wage regulations. In order to prevent this, we support the Government's determination that inspection supervision be non-selective and effective, but it is desirable to define additional stimulus measures for this sector of the economy in order to mitigate to a certain extent the effects of increasing obligations.

In order for the Program to be effectively and responsibly implemented, the Fiscal Strategy foresees a significant number of changes to existing and adoption of new legal solutions, in order to replace the budget revenues that will be reduced by the mentioned key measures (180-200 million euros), and in order to preserve the fiscal sustainability, and kept the deficit and public debt within the framework prescribed by the Maastricht criteria. First of all, changes to the Law on Value Added Tax, which foresees the introduction of a new rate of 15%, then the Law on Personal Income Tax, which expands the coverage of the tax base by introducing new taxes on certain activities (profits from games of chance - 15% , activities via the Internet and video games-15% and income that a natural person receives from another natural person -15%), then the Act on Excise Taxes and other laws.

In conditions of growing aggregate demand (increased wages, increased pensions, significant growth in public investments), rising excise taxes and VAT increases, it is realistic to expect a certain impact on inflation. It is expected that this impact on inflation will be limited, that is, less than the growth of aggregate demand, due to the high level of imports and the fact that the prices of imported products are formed on the international market. However, in the past, retail chains used the growth of aggregate demand to increase prices, which led the Government to limit margins on certain products several times. The expected weakening of barriers in global supply chains and the global reduction in prices, on the other hand, should affect the downward trend of inflation.

Assessment of fiscal projections for the period 2024-2027.

The fiscal strategy envisages a series of fiscal policy measures that will significantly affect the structure and quality of public finances. Continued reduction of the tax burden on labor, harmonization of excise policy with EU directives, reduction of the gray economy, reform of tax and customs administration, introduction of medium VAT rate, better management of tax debt - these are the main features of the fiscal policy in the medium term, which are defined in the Fiscal Strategy .

The Strategy states that a conservative approach was used during the preparation of budget revenue projections for the entire medium-term period, which the CBCG welcomes, especially in a situation where unforeseen shocks may occur that may result in revenues being lower than planned. The scenario of lower GDP growth and inflation given in the PER is not covered. After the implementation of the planned measures, the Strategy predicts that revenues in 2024 will amount to 2.772,6 million euros (38% of GDP), and that they will reach the amount of 3.081,2 million euros (35,8% of GDP) in in 2027. Despite the planned reduced contribution, the Government expects that in 2025 there will be an increase in income in the amount of 81,8 million euros. The main generator of income growth in 2025 will be an increase in income from VAT and excise duties, due to an increase in personal consumption and the introduction of a new VAT rate of 15%, then the introduction of new taxable categories in the tax system of Montenegro (taxation of winnings from games on luck and the implementation of the new legal solution in the part of organizing games of chance), but also the intensification of activities to suppress the gray economy and tax debt collection. There is a dilemma as to whether additional budget revenues are realistically planned, and whether this could lead to a budget deficit and public debt higher than projected.

Budget expenditures also have a growing trend in the next medium-term period and the fiscal strategy foresees an increase in budget expenditures from the level of 3.009,6 million euros (41,3% of GDP) in 2024 to the level of 3.364 million euros (39,1% GDP), which represents a growth of 12,31%. The dominant reason for the growth of budgetary spending in the medium term is caused by the growth of the capital budget, the growth of transfers for social protection and in the part of health care financing, as well as the implementation of new policies.

The Strategy does not specify steps in the direction of public administration reform and optimization of public administration. The creation of an efficient public administration, through the creation of an optimal number of employees, is one of the key conditions for the reform of public finances. In this direction, we suggest the application of good practice in this domain, as well as the use of technical assistance from the International Monetary Fund (IMF) in conducting the Public Expenditure Review, which would eliminate unproductive spending and enable the necessary rationalization of the number of employees in the public sector based on meritocracy.

CBCG supports the Government's plan to reform the wage system in the public sector by adopting a new regulatory framework, as well as the implementation of the Centralized Wage Calculation System. The mentioned steps will lead to a fairer division of tasks, responsibilities and evaluation of the complexity of tasks, in accordance with the best practices in EU countries.

The projected growth trends of budget expenditures tell us that in the coming medium-term period the Government has opted for a more intensive investment cycle, which will contribute to accelerating economic growth, which the CBCG supports. However, we point out that borrowing on the international market is unfavorable at the moment, which can lead to a constant annual increase in interest-based expenses.

In the Strategy, the government recognized the risk of unfavorable borrowing, and therefore the possibility of entering into an arrangement with the World Bank as part of the PBG (Policy Based Guarantees) arrangement, as well as the issuance of domestic government bonds for individuals (retail bonds), as done by Croatia and North Macedonia, which the CBCG supports. In this way, the necessary financial resources would be obtained on the domestic market, with lower interest rates than those that would be achieved by issuing bonds on the international market, while on the other hand, bond buyers would achieve a higher return on their funds than the one they get by depositing funds. at banks. However, it should be borne in mind that the domestic market has limited potential.

The projected budget deficit will range from 3,5% of GDP in 2025 to 3,3% of GDP in 2027. The CBCG welcomes the Government's effort to achieve the "golden rule" of financing in the next medium-term period, i.e. that current expenditures are financed from current revenues (current consumption surplus), while the main generator of the budget deficit will be the capital budget, the implementation of which will encourage economic growth and development, which will also affect the improvement of public finances in the future.

The projected level of public debt will average around 64% per year in the period 2024-2027. year, and the net public debt averages around 61,3% per year. However, the public debt in absolute terms is constantly growing in the next medium-term period. Public debt at the end of 2024 will amount to 4,61 billion euros (63,28%), while at the end of 2027 it will amount to 5,61 billion euros (65,2% of GDP), which represents an increase of one billion euros or 21,8%.

It should be borne in mind that the target share of debt in GDP can only be achieved if the planned rates of nominal GDP growth are achieved, because as stated, lower growth scenarios from the PER were not taken into account. Also, the potential deviation of the debt level from the planned values ​​due to the application of the European methodology ESA 2010 (European System of Accounts: 2010) should be taken into account, taking into account the requirements from negotiation chapter 17, as well as EC recommendations[1].

For debt repayment in the period 2025-2027. 2,15 billion euros will be needed in 829 (2025 million euros in 353,1, 2026 million euros in 971,7 and 2027 million euros in XNUMX). The strategy plans to provide funds for debt repayment through new debt. Along the lines of the recommendations of the EC, as well as the recommendations of the CBCG from previous years, we suggest that a Public Debt Management Strategy be created as soon as possible, in order to clearly define the method of borrowing, as well as creditors, and to create a clearer picture and define adequate courses of action, in order to orderly servicing of the public debt.

In the Fiscal Strategy, it is stated that a grant from the EU was provided for the construction of the highway (Andrijevica-Mateševo ​​section in the amount of 200 million euros) and the reconstruction of the railway infrastructure in the value of about 150 million euros. In addition, through the Growth Plan for the Western Balkans, Montenegro will have access to funds of around 400 million euros in the period 2024-2027. Additional investments in the fields of education, science, culture, tourism, health, sports are planned from the capital budget, which the CBCG supports, while encouraging that the mentioned funds are used efficiently and purposefully, in order to implement the projects according to the planned dynamics.

The introduction of budget inspection into the system of public finances, which is envisaged by the Strategy, is one of the solutions that the CBCG has proposed for many years as part of its Recommendations to the Government. Inspection supervision is the most effective form of protection of public interest and legality, in the part of using and spending budget funds of consumer units, municipalities and other public sector entities. Respecting the legal and purposeful spending and use of public funds should be the main goal of the inspection supervision, which will be at the center of the budget inspection.

Assessment of new fiscal policy measures on the revenue side

The fiscal strategy foresees numerous changes to the existing ones and the adoption of new legal solutions that accompany the Program for reducing the tax burden on wages and increasing the minimum wage in order to reduce the tax burden on wages, but also to replace the budget revenues that will be reduced by the mentioned key measures of the Program (180-200 million euros), all with the aim of fiscal sustainability. The dominant part of those laws refers to the change in tax policy, as one of the key tools for maintaining stability and ensuring the long-term sustainability of public finances.

Law on value added tax. Amendments to the Law on Value Added Tax envisage the introduction of a new rate of 15%, which will be applied to: books, monographic and serial publications; accommodation services in hotels, motels, tourist settlements, guesthouses, camps, tourist apartments and villas; services for the preparation and serving of food, beverages and beverages, except for alcoholic beverages, carbonated and non-carbonated beverages with added sugar and coffee in catering facilities; copyright and services in the field of education, literature and art; copyright in the field of science and artistic subjects; services that are billed through tickets, except for those for which VAT exemption is prescribed; services for the use of sports facilities for non-profit purposes, service services provided in marinas; solar panels; hairdressing services. Expanding the tax base and defining a new tax rate will result in an increase in income. However, any introduction of new forms of tax is very unpopular, so it can demotivate entrepreneurs or companies to engage in that business, it can affect the increase in the price of their services, but it can also affect the increase in the gray economy.

Law on personal income tax. Amendments to the Personal Income Tax Act provide for the expansion of the tax scope, i.e. increasing the tax base through an increase in the number of forms of income earned by a natural person, namely income from games of chance, from performing activities via the Internet and video games, and income that a natural person earns from another natural person. Thus, profits from games of chance will be taxed (15%), activities via the Internet and video games (15%) and income that a natural person receives from another natural person (15%). We believe that these measures are well defined.

Excise Law. Amendments to the Law on Excise Taxes provide for the expansion of the scope of taxed products: non-carbonated drinks with added sugar, still wines and "fuel labeling". CBCG supports the introduction of fuel marking, as this will improve both traffic control and fuel quality.

Law on corporate income tax. Amendments to the law on corporate income tax are planned to: introduce the right to exemption from corporate income tax, which will enable a legal entity that reinvests funds from realized profits in agricultural projects, as well as a legal entity that invests funds in other subjects of agricultural activity, to the calculated tax is reduced by the amount of funds that were reinvested, i.e. invested; reduction of the percentage and scope of recognition of expenses of legal entities that are recognized as expenses in the amount of 3,5% of total income. CBCG supports this solution, because any investment in agriculture, as one of the economic branches with huge development potential, contributes to increasing its competitiveness.

Law on write-off of interest on overdue tax liabilities. The adoption of the Law on write-off of interest on overdue tax liabilities, which will include the possibility of write-off of interest to tax debtors who settle the basic tax debt in full in the manner and within the deadlines provided by law, with the beginning of application from January 1, 2025, will enable better collection of tax debt, which will have a positive impact on budget revenues.

Law on games of chance. The adoption of the new Law on Games of Chance will create the basis for higher revenues from games of chance, assuming that it is applied consistently and indiscriminately.

The Fiscal Strategy clearly defines the intention to intensify activities to suppress the gray economy, in accordance with the Program for Suppression of the Informal Economy in Montenegro for the period from 2024 to 2026. Potential reserves that are not included in the revenue projections of the fiscal strategy are the Law on Confiscation of Assets Gained by Criminal Offenses, the airport concession and revenues from the legalization of illegally built buildings. The Central Bank encourages the start of the dynamic application of new penalties by supervisory authorities (institutions of the Government of Montenegro[2], along with the Central Bank of Montenegro and other regulators) in accordance with the Law on Amendments to the Law on Prevention of Money Laundering and Financing of Terrorism adopted by the Parliament of Montenegro. . July 2024, in order to achieve efficiency, proportionality and a deterrent effect in relation to taxpayers with identified systemic deficiencies, and in this way demonstrate to the European Commission and MONEY VAL the effectiveness of the system and the balance of good results.

Implications of the Fiscal Strategy on the PIO Fund

Reducing the burden on employers through allocation to the PIO Fund has positive aspects, but it also brings with it potential fiscal risks.

Reducing the contribution rate will increase the competitiveness of the economy, due to reduced labor costs, and have potential positive effects on reducing the outflow of labor force abroad. This is important, in the context of the need to preserve human capital due to the increasingly certain accession of Montenegro to the EU. The reduction of contributions to PIO can also reduce the gray economy in the part of informal employment, which the Fiscal Strategy predicts.

The fiscal strategy refers to the period 2024-2027. year, but it is desirable to look at the far-reaching consequences of the abolition of pension contributions. The risk of declining birth rates should also be taken into account, which in the long term may increase the mandatory costs for social transfers, while at the same time the life expectancy in Montenegro is increasing, which also affects the mandatory social transfers in the long term.

In this direction, the CBCG suggests that the fiscal strategy be supplemented with a long-term assessment of the impact of measures to reduce contributions for pension and disability insurance on the burden of the employee and the burden of the employer. It is a measure that systematically affects the income of PIO and pensions of employees, and the CBCG believes that it is necessary to simulate the amount of the pension in a similar way as it was done at the level of earnings with a horizon of up to 20 years. Also, we suggest that an assessment of the impact of these measures on the income and sustainability of PIO be done with a long-term horizon. Developed models of international financial institutions (IMF) can be used for these purposes.

It is clear that reducing the rate for pension and disability insurance requires higher mandatory expenditures for social transfers. It is planned that the financial gap in the PIO Fund will be compensated from other sources. Some of these sources are an increase in VAT, excise duty, an increase in consumption (and therefore the tax base), higher revenue collection than planned in 2024, a reduction in the gray economy (due to a reduction in informal employment), and others. In general, the economic impacts of revenue reduction on the one hand, and the economic-fiscal impacts of additional sources of budget revenues on the other hand, have not been explained methodologically to the end.

It was stated that "in the preparation of the analysis of the effects of the proposed program, during the quantification of the impact of the change in the minimum wage and the tax burden of work on the revenues and expenditures of the budget, i.e. the budget balance, as well as the impact on the business environment", the microsimulation model of the IMF and the methodology of Monstat were used. We suggest that the Annex should contain a description of the applied methodology (inputs, hypotheses, as well as the time frame to which the estimates relate), because only the results are presented, but it is not explained how they were arrived at. The document would be significantly improved if the scenario were applied analysis.

Implications of the Fiscal Strategy on the process of European integration

The adoption of the Fiscal Strategy will also create formal conditions for the preparation of the Medium-Term Public Debt Management Strategy for the period 2024-2027. year. The adoption of both documents is planned by the PPCG for the negotiation chapter 17 — Economic and Monetary Union for 2024 (second quarter), which contributes to a better assessment of the general progress in this chapter and the fulfillment of the third criterion for the temporary closure of this chapter.

In the Fiscal Strategy Proposal 2024-2027. the significance of the establishment of the Fiscal Council of Montenegro for the negotiation process with the EU, especially for the negotiation chapter 17 — Economic and Monetary Union, was highlighted. It was stated that the formal prerequisites for the establishment of the Fiscal Council of Montenegro were created by the Amendments to the Law on Budget and Fiscal Responsibility from 2023, as well as that "the next step is the election of the members of the Fiscal Council, after which the conditions for functioning and operational work will be created according to the competences".

Roadmap for fulfilling the third criterion for the temporary closure of negotiation chapter 17 — The Economic and Monetary Union envisages the formation of the Fiscal Council by the end of 2024, in order to fulfill the conditions defined by the Law on Budget and Fiscal Responsibility. The same deadline (2024) is defined by the Action Plan for Harmonization with the EU acquis in the area of ​​Chapter 17. Both of these documents were submitted to the European Commission. In this regard, the Central Bank recommends intensifying activities on the election of members of the Fiscal Council and avoiding delays in order to fulfill the obligations from the third criterion for the temporary closure of negotiation chapter 17. 5

Other implications

We value as positive greater alignment with EU directives through taxation of products that have a negative impact on health, which will have a positive effect on budget revenues. These products reduce life expectancy and productivity, and increase budget expenditures for healthcare in the long term.

The increase of the VAT rate on catering services from 7% to 15%, which the Government has assessed as indicative from the aspect of budget revenues, brings challenges that need to be further analyzed in the Strategy. We suggest that a comparative analysis of other competitive tourist destinations be done, because the increase in VAT on hospitality services can negatively affect the competitiveness of the Montenegrin tourist offer. Bearing in mind the weak diversification of the Montenegrin economy, as well as the significant impact of tourism on economic growth, the effects of the influence of these policies should be quantified. It is important to analyze these effects, because the given macroeconomic scenario is based on the further growth of the tourism sector during 2024-2027.

The fiscal strategy has recognized in a good way that one of the goals of the thematic policies is the energy/green transition in view of the growing climate risks and the need to realize the Green Agenda for the Western Balkans of the European Commission. 7 We believe that it would be useful to additionally look at and take into account the necessary measures and instruments in order to significantly speed up and implement it in accordance with the assumed obligations and determination that the digital and green transition will contribute to the long-term economic stability and sustainable development of Montenegro.

Good practice also refers to the possibility of using artificial intelligence (AI) for the purpose of collecting tax revenues, i.e. identifying tax evasion. Al algorithms can detect patterns and anomalies in large data sets, identifying potential tax evasion or fraud. AI can analyze taxpayer behavior and predict non-compliance, allowing tax authorities to focus on high-risk cases. Automation of tax processing and data analysis reduces administrative costs and accelerates revenue collection. Also, AI can provide personalized guidance to taxpayers, improving compliance and reducing errors. These applications help governments optimize tax collection and increase revenue.

The fiscal strategy included numerous other aspects of public policies, such as wages in the public sector, state-owned enterprises, digital transformation of public administration and the health system, public investment management, the labor market, environmental protection, the financial sector, and others. The fiscal strategy recognizes these problems in an adequate way and foresees reforms in these areas that will improve the quality of life of citizens.

The transformation of the IRF into the Montenegrin Development Bank in accordance with the technical assistance recommendations of the European Investment Bank from 2023 is of key importance for valorizing the growth potential and increasing the competitiveness of the Montenegrin economy.

The CBCG's suggestions relate to the activity of receiving deposits, the activity of providing payment services, user protection, election of bank authorities, publicity of work, reporting and business control. Alignment with relevant European regulations should contribute to a clear profiling of the future institution as a development financial institution based on generally accepted standards of development financing or as a credit institution equal to all other credit institutions on the domestic banking market.

The establishment of the Credit-Guarantee Fund is an activity planned by the Fiscal Strategy. CBCG provides support to complete the establishment within the defined period, so that the Montenegrin economy can benefit from easier and more efficient access to financing. This solution will significantly improve the situation in the real sector, which will be reflected through the reduction of the illiquidity of the economy and the easier and faster provision of financial resources necessary for starting or expanding business with a special emphasis on micro, small and medium enterprises, and vulnerable categories that include women, young people and agricultural producers.

CBCG welcomes the Government's intention to improve corporate governance and the establishment of a supervisory function through the reform of state-owned enterprises, which will, among other things, be reflected in the assessment and monitoring of financial and fiscal risks of their operations.

Also, we suggest creating a central register of employees in the public sector (general and local level of the state), including employees in majority state-owned enterprises in order to identify redundancies and overlapping responsibilities and perform a functional review that would be useful for optimization in the future .

The fiscal strategy included a series of measures aimed at improving the business environment, which is encouraging, because Montenegro, as an open and small economy, must have an attractive environment for foreign investors, especially taking into account the structure of FDI. In that part, we welcome the plan and effort to improve seasonal employment through the Law on permanent seasonal workers, provide easier access to the labor market during seasonal work and ensure the rights of permanent seasonal workers for the period when seasonal work is not performed.

In addition, the planned Law on Foreigners envisages the creation of prerequisites for electronic application and approval of work permits for foreigners, which will shorten the procedure for approval of these permits. In terms of improving the business environment, the CBCG suggests paying more attention to suppressing the gray economy through the implementation of the Program for Suppressing the Informal Economy in the period 2024-2026. year, as well as the development of a new action plan for the implementation of the mentioned program. We suggest that the funds necessary for the successful implementation of the mentioned program be reserved in the budget, in order to create multiple benefits for the entire economy of Montenegro.

It is necessary to harmonize the sentence on p. 70 Fiscal strategy proposal that reads: "After a positive EC opinion, Montenegro will formally submit an application for the expansion of the SEPA geographical area to Montenegro, which is expected at the beginning of July 2024" with the fact that the Central Bank of Montenegro l . In July 2024, on behalf of the State, it formally submitted an application to join the Single Euro Payments Area (SEPA).

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