INTERVIEW Laketić for "Vijesti": Interest and controls have increased tax debt

The total tax debt in Montenegro currently amounts to around 750 million euros. According to official data from the "black list", the 200 largest tax debtors owe more than 95 million euros, and an additional 100 bankrupt tax debtors owe around 130 million euros, which means that around 225 million euros of tax debt is on these two lists, with the largest part related to legal entities.

This was stated by the Director of the Tax Administration in an interview with "Vijesti". Sava Laketic.

"Tax debt is mainly increasing due to the growth of interest, which amounts to 0,03% per day, and represents a significant amount of debt, especially for taxpayers with older debts. The growth of tax debt is to a significant extent a consequence of inspections conducted and subsequently determined tax liabilities. During tax audits, undeclared or incorrectly calculated tax liabilities are determined. Such corrections increase the total tax debt, although these are not newly incurred debts, but liabilities that existed but were not properly recorded. Therefore, the current increase in tax debt should be observed both through the results of inspection supervision and through their activities to detect and record previously undeclared tax liabilities," said Laketić.

According to him, it is important to note that the movement of the total tax debt in 2026 was also influenced by the implementation of the latest reprogramming of tax liabilities of municipalities, funds, public institutions and companies founded by local self-government units, implemented in accordance with the law.

"The biggest challenge remains the collection of old tax debt, part of which is difficult to collect or uncollectible. Of the total debt, around 300 million euros refers to accrued interest. Although the Tax Administration has recorded continuous growth in collection in recent years, the total accumulated tax debt continues to grow," Laketić pointed out.

The issue of writing off uncollectible tax debt has not been resolved for years. Why has this process not yet been implemented, what are the main obstacles, and when can we expect the debt that is certain to be uncollectible to finally be written off?

According to the applicable regulations, the basis for assessing the collectability of a tax debt is, first of all, the occurrence of absolute statute of limitations on the right to collect tax liabilities, in accordance with the Law on Tax Administration. On this basis, regional units and branches continuously issue decisions on the termination of tax liabilities, but the dynamics are not at a satisfactory level, and on this basis organizational and procedural changes are being implemented. Also, from the aspect of the collectability of tax claims, it is important to separate the debts of taxpayers against whom bankruptcy proceedings have been opened, the completion of which also depends on the eventual collection.

The plan that we are actively implementing for the purpose of more efficient collection of tax debts is based on several key measures envisaged by the Fiscal Strategy, the Public Finance Reform Program and the activities of the Tax Administration, namely the digitalization of the Tax Administration, i.e. improvement of the information system, automatic data exchange between institutions and better risk analysis in order to identify debtors earlier, then increased forced collection in the form of account blocking, execution on property and other legally prescribed measures against debtors who do not settle their obligations voluntarily, better assessment of the collectability of tax claims, as well as encouraging voluntary payment through electronic services and notifications to taxpayers.

What is the amount of tax debt that the Tax Administration estimates to be uncollectible and what is the structure of that debt? Does it mostly relate to closed companies, bankruptcies or other cases?

The Tax Administration is continuously working to improve tax debt management, which includes classifying tax receivables according to their collectability. This process involves checking data quality, harmonizing records, and analyzing the status of each individual taxpayer, in order to clearly distinguish between collectable, uncollectable, and potentially uncollectable debt.

I must emphasize that precisely determining the exact amount of uncollectible debt is a demanding process, given that the status of individual taxpayers changes depending on status changes, the outcome of bankruptcy and liquidation proceedings, as well as other circumstances that affect the possibility of collection.

What I can say with complete certainty is that the Tax Administration does not give up on collecting receivables as long as there is a legal basis and a realistic possibility for doing so, and that the uncollectibility of a debt is not determined arbitrarily, but exclusively through a prescribed procedure and based on the documented status of the taxpayer.

At the end of last year, the parliament adopted a law that allowed municipalities, funds, public institutions and companies founded by local governments to reschedule their tax debt for taxes and contributions in installments with a write-off of interest and costs. What was the total amount of tax debt that could have been covered by this law, how much of that debt has been rescheduled so far, and how much has been collected on that basis so far?

The law that enabled municipalities, funds, public institutions and companies founded by local governments to reprogram their tax debt with a write-off of interest and costs represents strong support for the stabilization of local finances, and its effects can already be measured through the concrete results of its implementation.

Based on this law, 55 decisions on rescheduling have been adopted and implemented. The total amount of rescheduled obligations based on the principal debt amounts to 54,5 million euros, while the accrued interest on outstanding due obligations amounts to 21,5 million euros.

Some taxpayers took advantage of the legal opportunity to include in the new reprogram liabilities that were previously included in the 2015 reprogram, including those liabilities that were not yet due for payment under that, older reprogram. In this way, all their liabilities were consolidated into a single reprogram, which, on the one hand, makes it difficult to simply compare with the starting base, but on the other hand, it facilitates further monitoring and analysis of the settlement of liabilities because there is now one consolidated overview for each taxpayer instead of multiple parallel records.

Regarding the collection so far, by reviewing the official records, we can confirm that taxpayers included in the latest reprogram are regularly settling their obligations. So far, in accordance with the conditions set out in individual reprogram decisions, two due installments have been paid.

Do debtors who have concluded rescheduling agreements regularly pay their installments and have there been any terminations of contracts due to non-compliance with the obligations undertaken? If so, how many cases are there and what is the amount of debt covered by the terminated agreements?

We are currently monitoring the implementation of four tax rescheduling and deferred payment programs, established on the basis of various legal solutions adopted in the previous period. These are the 2015 tax rescheduling of municipalities and their companies, concluded between the Ministry of Finance and municipalities, the deferred payment program implemented in accordance with the 2018 Regulation; the 2022 tax receivables rescheduling, as well as the latest 2025 tax rescheduling of local government units, funds, public institutions and companies founded by local governments.

The implementation of each of these programs involves continuous monitoring of the fulfillment of contractual obligations, control of compliance with the established repayment schedule, as well as taking legally prescribed measures in cases where the taxpayer does not meet the reprogramming conditions. This approach, debt deferral and payment in installments, has proven to be an important instrument for tax debt management, contributing to an increase in the level of collection and a reduction in the total recorded tax debt.

The best results were achieved by implementing the 2018 Regulation on Deferred Payment of Tax Liabilities; this model proved to be the most efficient instrument for settling due liabilities, with a collection rate of 96 percent.

The 2022 reprogram has shown weaker results, with a realization rate of just over 60 percent. This means that a significant number of taxpayers, out of a total of 5.209 who entered this reprogram, have not fully fulfilled their obligations in accordance with the established payment schedule. To answer your question directly about terminations: yes, there have been cases of reprogram cancellations due to non-compliance with the conditions. Decisions on the cancellation of the reprogram were issued for 780 taxpayers, which include a total claim of around 64,5 million euros.

When it comes to the 2015 municipal tax debt rescheduling, the implementation is at an enviable level in the part related to the settlement of the agreed monthly installments. It should be noted, however, that municipalities, public institutions and companies included in that rescheduling did not always settle their current liabilities in a timely manner in parallel with the installments of the old rescheduling. This is precisely one of the reasons why the latest rescheduling from 2025 was introduced, so that these subsequently incurred, outstanding liabilities could also be legally included in the new repayment agreement.

Since its implementation this year, the Tax Administration's new Integrated Revenue Management System (IRMS) has been accompanied by numerous complaints from businesses, citizens, and the accounting profession, from difficulties in filing tax returns and registering companies to problems with issuing certificates and accessing the portal. To what extent have these problems been resolved today, how many reports of technical difficulties have been recorded since the system began to be implemented, and is the IRMS now operating at full capacity?

The Integrated Revenue Management System (IRMS) represents the first major step towards a modern tax administration, but also an important part of the broader digital transformation of public administration. As with any complex system of this scale, the initial phase of implementation was accompanied by certain technical difficulties and a period of adjustment, both for our officials, accountants and the economy. This was expected and foreseen, similar projects in other countries, and on a much smaller scale, were implemented gradually and lasted for several years, while Montenegro, due to a significant delay in the implementation of the project, and in accordance with the obligations assumed from the EU integration, was in a situation to replace all modules at once.

Each of the identified difficulties was recognized in a timely manner and systematically resolved, in partnership with the economy and professional associations, with continuous support and education of users. In the first months of implementation, challenges in the registration procedures stood out in particular, where processes were disabled not because of the IRMS itself, but because of the incompatibility of legal solutions. In other words, part of the problem was not the question of whether the system could receive or process the request, but how a certain procedure should be implemented when the new digital process encounters old normative and administrative forms, and it was precisely this segment that was the subject of additional harmonization of regulations at the end of March 2026.

Since the system went into full production, the vast majority of identified technical difficulties have been resolved, and the remaining improvements are being implemented through a regular stabilization and improvement phase, based on real-world cases.

As for the question of whether the system is currently functioning at full capacity, it is important to emphasize that we do not view IRMS statically, nor in isolation from the systems of other authorities. It is a living system that requires continuous adaptation to legal changes, technical adjustments, improvement of the level of connectivity with other institutions, and the like. What I can confirm is that the scope of use of the system is continuously increasing, that the number of processed cases has reached 180.000, with a record June with over 50.000 processed cases, and that the system of automatic information exchange has been improved with a large number of institutions.

How much tax has the Tax Administration collected since the beginning of the year through increased controls and forced collection measures, how many cases of tax evasion have been discovered, and in which sectors have the greatest irregularities been observed?

Since the beginning of the year, inspectors from our Group for Risk Analysis, Selection of Cases for Control and Reporting have submitted a total of 64 pieces of information to the Police Directorate, in order to determine whether there are elements of criminal liability in taxpayers who have been found to be in violation of tax regulations.

Based on further proceedings, the Police Directorate has filed a total of 13 criminal charges against legal entities and their executive directors since the beginning of the year due to grounds for suspicion that they committed the criminal offense of tax and contribution evasion over an extended period, which caused material damage to the budget of Montenegro. The total amount of taxes and contributions covered by these criminal charges is 1,7 million euros.

When it comes to the activities in which the greatest irregularities were observed, the largest number of criminal reports filed refers to taxpayers engaged in construction activities, followed by trade and hospitality.

I would like to emphasize that cooperation with the Police Administration in this segment is continuous and that the Tax Administration consistently reports every case in which there is a reasonable suspicion of a criminal offense to the competent authorities, regardless of the size of the taxpayer or the activity it engages in.

We have not given up on taxing lawyers, the number of registered lawyers is growing

The issue of fiscalization of the legal profession is still unresolved. Has this process been abandoned or is the Tax Administration still working on its implementation? If not, what are the current main obstacles and when can we expect lawyers to be included in the fiscalization system?

The Tax Administration has not given up on the process of fiscalizing the legal profession, nor is it an option we would consider. The legal profession, like all other activities that generate turnover of products and services, is subject to the legal obligation to record that turnover through the electronic fiscalization system, there are no exceptions or deviations from the law.

As of the current situation, 579 taxpayers have registered for fiscalization so far. It is important to note that the number of registered taxpayers is continuously increasing, with a significant increase in early 2026.

For lawyers who are found to be not complying with the fiscalization obligation during the control process, the law prescribes a fine ranging from 2.000 to 12.000 euros, and the Tax Administration consistently applies this measure within its jurisdiction.

The work on the full coverage of this activity by the fiscalization system is a continuous process, which we are implementing through regular control activities in the field and constant communication with the Bar Association, with the aim of including any non-fiscalized taxpayers in the system as soon as possible. Based on the current dynamics, we expect that this number will continue to gradually increase, and the Tax Administration will continue to monitor the implementation of this obligation until the activity is fully covered.