"Instead of the relevant ministry (Ministry of Culture) helping the project, which I didn't even ask for, it blocks everything... I wondered if I, as a citizen, an artist with a reputation, have any rights in this country"...
Such an academic painter Goran Ćetković briefly conveys his feelings ahead of one of the exhibitions outside Montenegro, for which he waited a long time for a license to export paintings, issued by the Ministry of Culture and Media of Montenegro. He got the permit after posting it on social networks, and in the shortest possible time, just before the announced opening of the exhibition.
His case is not the only one. In recent years, there have been more frequent complaints from visual artists about the lack of promptness of the relevant ministry in issuing the necessary documentation for the exhibition of works of art outside of Montenegro, specifically for the export of works.
When (it seems) everything falls apart
Opening of the exhibition "More pictures from today's walk" Srđe Dragović i Milena Vukoslavovic in mid-October in Belgrade, it was uncertain, because Milena was waiting for the permit for the export of works issued by the MKM.

"Three days before the opening of the exhibition, we informed the organizers that we will most likely cancel the exhibition and that it is necessary to consider a new date", says Vukoslavović for "Vijesti".
89
requests for the export of art were received by the Ministry of Culture during the previous 17 months, and all of them were answered within the legal deadline, claims Hristina Bošković
However, the exhibition was opened on October 12 in the gallery of the Studentski grad Cultural Center. It is an expanded edition of the exhibition that took place last year in the Modern Gallery in Podgorica.
Ćetković had a similar experience that he shared with the readers of "Vijesti" before. He sees the promotion of his own creativity as the realization of one of the basic human rights.
"There has been a kind of confusion and lack of up-to-dateness in cultural institutions for the past few years, which is causing art to suffer, that is, the artists themselves who present themselves abroad," says the painter, commenting on the issuance of permits for the export of paintings.
Ćetković often exhibits abroad, either independently or to participate in collective exhibitions, so he knows the procedure well. For "Vijesti", he recalled the uncertainty before last year's exhibition.
"I had a very difficult situation in 2022. My solo exhibition was being prepared at the 'Lucida' gallery in Belgrade. I financed the entire project from my personal funds. A month before the exhibition, I submitted the complete documentation to the Ministry of Culture. In a conversation with some individuals and owners of galleries in Montenegro, I came to believe that my documentation will not be ready because they have been waiting for it for months," says Ćetković, who emphasizes that he could not believe that, nor did he want to believe it.

"Specifically, I have been exhibiting abroad since 2005 and this type of paperwork was completed in one day. However, as my exhibition approached I realized that the papers would not be completed according to the deadline. So worried, I call the Ministry of Culture and get the answer that the papers will not be completed. So everything falls into the water?! Three years of work on the project, a printed catalog, posters, invitations sent, an art critic hired for the opening, an already organized and paid freight forwarder and a lot more effort... I shared my problem on social networks and the next day, with the quick reaction of the spokeswoman of the Ministry of Culture, the situation was resolved for half an hour," says Ćetković.
This is proof that prompt reactions are possible, so the question arises as to why the procedure takes so long.
"Depending on the nature and justification of individual requests, MKM in quite a few cases supports the participation of artists in reference international events. The Commission assesses the justification of the request in each specific case, and it depends on the submitted documentation and the budget specification of other relevant acts, on the basis of which it can be decided on the importance of the artist's creative work and possible financial support. MKM, not only when it comes to independent and collective exhibitions of artists from the art industry, but also other requests from the domain of cultural and artistic creativity, strives to respect the nature of the request itself and respond to all requests within the legally stipulated time," she told "Vijesta" until recently spokeswoman for the Ministry of Culture and Media Hristina Bosković, who covered that position during the mandate of Minister Vlaović.
It can be done easily and quickly, but it is complicated and takes a long time
Answering the questions of "Vijesti" on this occasion, Bošković emphasized that the MKM "continuously works to improve the position of artists in Montenegro and the development of the Montenegrin cultural scene". She reminded that the Law on Administrative Procedure sets a deadline of 20 days for issuing the necessary approvals, from the day the approval was requested, provided that the documentation is in order and complete.
"Especially speaking about the segment related to the export of art, we are pleased to point out that the administration of the MKM managed to respond within the legal deadline to all 89 requests received in the previous 17 months," added Bošković.
That 20-day deadline was problematic for Vukoslavović.
"When exhibiting outside the country, certain documentation is required in order to transport the works across the border: an ATA carnet, issued by the Chamber of Commerce, and a permit for the export of works issued by the Ministry of Culture. I submitted the documentation required for issuing the permit to the Ministry on September 20, and the deadline for transporting the works was October 10. I expected that the permit would be issued during that period without any problems, because I received the ATA carnet for all works in the Chamber of Commerce in less than 48 hours", says Milena.
On the day of submitting the documentation to the Ministry of Culture, she did not receive any information about how long the permit is waiting for, she says. The date of the opening of Dragović and her exhibition was approaching, thus the deadline for departure to Belgrade, and there was no response from the MKM. Then the artistic duo decided to inform the organizers about a certain cancellation or postponement of the exhibition.
"Of course, we also put the organizers in trouble, who initially recommended our exhibition to the Cultural Center of the Student Town, because the program of that institution is planned precisely a year in advance. Fortunately, on the same day when we were considering new dates for the exhibition, I was informed that the permit was ready and that I could take it over," says Vukoslavović.
Our cultural institutions must not be a brake for the realization of artistic projects, but, on the contrary, a tailwind", says Goran Ćetković.
She says that the problem was that she "submitted the necessary documentation late", compared to the deadline for issuing the permit...
"I believe that it is necessary to clarify why there is so much waiting for the issuance of that document. I spoke with colleagues from the region, and for the same document in much larger countries, with incomparably more requests, it only takes a couple of working days", emphasizes Vukoslavović.
Artist from Belgrade Irena Kuzmanović confirms that.
"Everything will be finished within three working days, although I don't even remember waiting that long. It's usually over in a day or two. They are brilliantly organized and very friendly. Also, everything on the site is nicely explained step by step", Kuzmanović told "Vijesta".
When asked what the procedures are when exhibiting Montenegrin artists abroad, Bošković replied that all those interested can get information on the website of the MKM. Ćetković, based on his experience, brings them closer to the readers of "Vijesti".
"Given that Montenegro is not a member of the European Union, you must have an ATA carnet for all countries to which you exhibit, that is, 'export images'. It is a permit for the temporary export of images abroad. You can get an ATA carnet in your country, that is, at the Ministry of Culture, the National Museum and the Institute for the Protection of Cultural Monuments. This document contains photographs of the paintings and all other information about the works you are exhibiting. Finally, they are certified and stamped by the Ministry of Culture. With that documentation, you go to the Chamber of Commerce, where you get the final permission to export images. With such proper documentation, you can export pictures to another country," he said.
Ćetković believes that all paperwork can be completed routinely, simply and in a short period of time.
"I have information, through colleagues from Zagreb and Belgrade, that the ATA carnet in those countries ends in one day. This was the practice in Montenegro until a year ago," he says.
Kuzmanović confirms this and explains how things work in the neighboring country.
"In Serbia, the procedure for issuing a permit for the export of works is to fill in the form found on the website, to which a photo of the work is attached with technical data about the work (so the basics: dimensions, year, technique...) and it can all be delivered in person or sent by email. When you send by email, on the same day you receive from them photos of two payment slips, with the number of your item. It is paid for, and I usually take photos and send payment slips. You can go for the permit in person or send it by mail - depending on how you check the field," Kuzmanović explained to "Vijesta".
The form for "Permit for permanent/temporary export of art from Montenegro" is available on the eGovernment of Montenegro portal. The procedure begins with the submission of the request of the party (natural or legal person) to the department of culture, then an opinion is obtained from the Administration for the Protection of Cultural Property, which determines the status of the item (whether it is a cultural property). Opinion of the Administration for the Protection of Cultural Property, opinion of the parent institution of culture, completed application, proof of paid administrative fee in the amount of 10 euros.
The required documentation that should be attached for the issuance of a license is the Request of the party, which contains the following information: name or title of the applicant and address and headquarters, information about the object, name of the author, dimensions, manufacturing techniques, country to which the object is exported, total value, type of export, date of exit, and for temporary removal the date of return, the address where the item will be located, the purpose of removal. The Ministry issues a permit based on the previously obtained opinion of the Administration for the Protection of Cultural Property, with certified photo documentation in 4 copies, a list of objects if more than one art is being exported. After the mentioned document, in which it is stated that the works of art do not have the status of cultural property, the exhibition is approved and a permit is issued.
The deadline for issuing a license is, as "Vijesti" interlocutors stated, 20 days, and the period of validity is one year when all legal requirements are met.
Simpler procedures in everyone's interest
Vukoslavović suggests that it is necessary to simplify the procedure in force in Montenegro.
"According to the experiences of colleagues from the region, this process can easily be done through digital platforms. This would reduce costs for both institutions and artists, and overall facilitate the process of collecting documentation for the transport of works," she claims.
Ćetković says that for every author, representation abroad is extremely important, because these are ideal opportunities for promoting the artist's creativity, as well as the country's. In this context, artists should be encouraged, not sabotaged, not even indirectly or unconsciously...
"Our cultural institutions must not be a brake on the realization of artistic projects, but on the contrary, a tailwind," says the academic painter.
Vukoslavović believes that nothing guarantees a timely response from the competent department and advises that the only way to avoid the scenario she went through is to submit the documentation for the permit as soon as possible...
"So that there is enough time to prepare the document - this is the feedback we received from the Ministry", the artist reports to "Vijesta" and states that this is not always feasible, given the fluid nature of artistic creation...
"It is clear to us what the circumstances were, but due to the work on the latest pictures that I intended to transport, there was no way to start collecting the documentation earlier. For the ATA carnet and permit, it is necessary to have a photo of the finished work," she explained.
However, she claims that even that approach, where it is necessary to submit the documentation as early as possible, did not help several of her colleagues.
"They simply did not get the permit. So, because of the issuance of one document, a situation has arisen in which the author simply misses the opportunity to exhibit abroad, or, for example, the chance to sell the works fails," says Vukoslavović.
Ćetković is not surprised by the procedures, nor by individual cases, and reminds us of the general bad state of culture, and then also in his sphere.
"I think that in our country there is no clear strategy for many things, not only for culture. The institutions of the system are still confused. We see that we cannot take out a single piece of paper without a lot of trouble. I rely primarily on myself, my work and quality. Our Association of Fine Artists of Montenegro was transformed into a non-governmental organization. So much for investing in fine art! In the last decade, the presentation of our art scene abroad has not been organized. There are only artists - individuals who, by their own efforts, promote the country they come from and their art. Of course, if you have quality, then some invitations for quality art projects will come," says Ćetković.
Vukoslavović notes that "some employees of the Ministry of Culture have shown understanding for this case".
"Because in the end, only thanks to that, the permit was issued and the exhibition was opened within the agreed time. Even so, I believe that communication could have been more regular, the instructions on deadlines clearer, the procedure more transparent. We made calls to the Ministry because we were told that we can count on help. This does not condition us in such a way that it is forbidden to send constructive criticism to the Ministry, since such situations can be avoided, and the procedure can be simplified for the benefit of both the author and the institution", says the artist.
Tax on sold pictures and regulation of ATA carnet - in another country
When asked whether fine artists pay a certain amount of money for representation abroad, and then possibly a tax on purchased works, considering that many exhibitions are of a sales nature, Ćetković again emphasizes that "many things are not favorable to artists".
"I already mentioned the EU. There are clear rules there. At many important salons, a registration fee is also paid. Of course, when it comes to the sale of paintings, tax is paid. The same happens when your pictures are under the ATA carnet. If you sell pictures, there is a procedure for paying taxes on those pictures, as well as additional regulation of the ATA carnet in the country where it happened. Not a simple procedure, but that's how it is. Standards must be respected," he comments.
He goes on to talk about what the procedure is at the border crossings when artists leave and export works of art, and what they are like when returning...
"The procedure at border crossings is not simple, but it is routine. You have an ATA carnet that must be stamped and certified by all customs checkpoints of the countries you enter. The same is done on the way back. In the event that all customs, i.e. all border crossings do not stamp your ATA Carnet - you may bear the consequences. For these reasons, it is best to hire an experienced and professional freight forwarder," he suggests.
The artist's engagement is conditioned by the currents on the domestic scene
The promotion of artists is only one of the segments that affirm the cultural diversity of all spheres of creativity, and the engagement of fine artists is conditioned by the currents on the fine arts scene, said, among other things, Hristina Bošković when she was the spokeswoman for the Ministry of Culture and Media.
"The way in which, to a greater or lesser extent, creative potential is marketed to the general public is one of the measures included in the National Cultural Development Program of Montenegro 2023 - 2027," she said.
Bonus video:
