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TAXACO SRL
str. Calea Iesilor 8/1,3rd fl, of. 9a
MD2069, Chisinau,
Moldova
+373 22 211 819
https://www.taxaco.md/
Iuri Cicibaba
Managing Partner
+373 69 325 938
icicibaba@taxaco.biz

Moldova

Corporate taxes and other direct taxes

General CIT is 12%. To compute taxable profit, the accounting profit is adjusted upwards (with non-deductible expenses) or downwards (with non-taxable revenues). Tax losses are carried forward for 5 years.
For CY 2023-2025, a special tax relief is being applied for limited liability companies and joint stock companies that represent SME (small and medium enterprises) – CIT calculated for CY 2023-2025 is paid to the State Budget only in the case of dividend payments. This tax relief is not applied to financial and insurance companies.

Moldova has a treaty network consisting of 50 double tax treaties. The WHT rate on dividends is 6%, while for interest and royalties it is 12%.
Capital gains from the sale of shares and other capital assets are taxable for non-residents – at 12% for legal persons; for individuals, only 50% of the capital gain is taxed at the rate of 12%. The relevant double tax treaties are applicable.

A compulsory micro-company scheme is applicable for companies not subject to VAT and with revenues below MDL 1,200,000 (approx. EUR 58,500) for a calendar year:
• 4% on total revenue
A microenterprise may opt for the CIT regime if it fulfils the following:
• it becomes a VAT payer;
• more than 50% of its revenue is generated by VAT-exempted supplies

A special tax regime applies for residents of IT Parks (Law No 77/2016): 7% on monthly sales income, but no less than MDL 3,510 per employee per month (Unique Tax). This regime is available for the period until 2037 inclusive. 70% of the sales generated by a resident should correspond to the list of IT services approved by law (including 3D programming and R&D). Starting February 12, 2024 the Law is also applicable to Business Process Operations Outsourcing that is 100% provided to exports.
This unique tax includes all payroll taxes, social insurance contributions, compulsory state health insurance, and all local taxes. Consequently, a resident of an IT Park is liable for a special tax, withholding tax, and VAT.

Transfer pricing in Moldova
Arm's length principle

Since 2024 for operations that cumulatively exceed EUR 1,000,000.

Documentation liability Since 2024
APA  
Country-by-Country liability
 
Master file-local file (OECD BEPS 13) applicable Since 2024
Only Local file rules are applicable.
Penalty    
- lack of documentation EUR 15,500 -51,670
- tax shortage  
Related parties Minimum
of
25%
Direct or indirect control. 
Safe harbors  

Level of attention paid by Tax Authority:
N/A

VAT and other indirect taxes

The general rate is 20%. Reduced rates are 8% (e.g. bread, milk and dairy products, medicines, natural gas, agricultural products, etc.) (hotel accommodation, restaurant services).
VAT-exempt activities include medical services, financial and banking services, insurance and reinsurance, sale and rental of land and residential premises (houses and apartments), certain types of educational and training activities, and other activities of public interest.

Other indirect taxes applicable include excise and environmental tax.

VAT options in Moldova Applicable / limits
Distance selling
Call-off stock
VAT group registration
Cash accounting - yearly amount in EUR (approx.)*
Import VAT deferment AEO, tax on goods is paid no later than when custom clearance is performed.
Local reverse charge Sale of collaterals and property of bankrupt entities.
Option for taxation
- letting of real estate  Land and residential premises are exempt.
- supply of used real estate VAT is not calculated for individuals on real estate transactions
VAT registration threshold* approx. EUR 58,800

Personal income tax / Social security system

A 12% flat-rate tax is applicable to revenues obtained from dependent activities (e.g. employment or activities assimilated to employment) or independent activities (freelancers). Annual personal exemption is applied to the amount of EUR 1,350.

Social Security Contribution (24% – employer part) and Health Insurance Contribution (9% – employee part).
Dependent activities are subject to HIC at the employee (9%) and SCC at the employer level (24%).
A 24% SCC rate is applied to meal vouchers.
The minimum monthly gross wage for the period starting January 1, 2024 in the real sector is MDL 5,000 per month.

Wage related taxes
in Moldova
Minimum wage
 
Average wage
in private sector
Exchange rate MDL/ EUR  in EUR in MDL in EUR in MDL
19.35 258 5,000 780 13,700
Total wage cost 320 124.00% 878 124.00%
Vocational training contribution  -   -  
Social Contribution tax 62 24.00% 170 24.00%
Health Insurance Contribution -   -  
Gross salary 258 100.00% 708 100.00%
Personal income tax* 14 12.00% 63 12.00%
Employees' Social contributions -   -  
Employees' Health contributions 23 9.00% 64 9.00%
Net salary* 221 86.83% 581 82.39%

*Personal tax excemption in the amount MDL 27000 is applied annually (27000/12 monthly)