Page 38 - CEE Tax Guide 2025

Moldova

Forvis Mazars SRL
str. Calea Iesilor 8/1,3rd fl, of. 9a,
MD2069, Chisinau, Moldova
Phone: +373 22 211 819
www.taxaco.md

Corporate taxes and other direct taxes Non-Resident Legal Entities: Taxed at 12% on capital
gains from shares and other assets.
CIT rate of 12% for resident companies. Reduced Non-Resident Individuals: 50% of the capital gain
rate of 7% for Farming Entreprises.
is taxable at 12%, effectively resulting in a 6% tax
Tax losses can be carried forward for up to five on the total gain.
consecutive years following the year in which the
losses were incurred, provided the company records Companies not registered for Value Added Tax (VAT)
taxable income. and with annual revenues below MDL 1,200,000
Special Tax Relief for SMEs (2023—2025) – CIT (approx. EUR 58,500) qualify for the micro-company
is payable only when dividends are distributed, taxation scheme at 4% tax on total revenue.
financial institutions and insurance companies are IT Park Tax Incentives:
not eligible.
Moldova has a network of 51 double tax treaties Special Tax Regime: Residents of IT Parks (Law
(DTTs) as of 2025. No 77/2016) benefit from a single tax rate of 7%
Dividends: The withholding tax (WHT) rate is 6% for on monthly sales revenue. This tax replaces several
both residents and non-residents. other taxes, including corporate income tax,
Interest and Royalties: A 12% WHT rate applies personal income tax, social security contributions,
to payments made to residents and non-residents. health insurance contributions, local taxes, real
estate tax, and road usage tax.
Minimum Tax per Employee: The single tax must not
Transfer pricing in Moldova be less than 30% of the average monthly salary per
Arm’s length principle For transactions that employee forecasted by the government for that
cumulatively exceed year. (MDL 16,100 the minimum monthly tax at MDL
MDL 20,000,000
(approx. EUR 1,000K). 4,830 (EUR 256).
Eligibility Criteria: At least 70% of a resident’s sales
Documentation liability Since 2024 must derive from IT services listed in the law,
APA APAs available for including software development, technical
up to 5 fiscal periods. consultancy, and data processing.

Country-by-Country No – Since February 12, 2024, the export of Business
liability Process Operations (BPO) services have been added.
Master file-local file Only Local file rules Scope of the Single Tax: The single tax covers
(OECD BEPS 13) are applicable.
applicable all payroll taxes, social insurance contributions,
compulsory state health insurance, and all local
Penalty
taxes. Consequently, IT Park residents are only liable
lack of documentation MDL 300,000—MDL for the special tax, withholding tax, and VAT.
500,000 (approx. EUR
15,300—25,600)
VAT and other indirect taxes
tax shortage No –
Related parties Min. Direct or indirect control. Standard VAT Rate:
of 25% 20% for most goods and services.
Safe harbors No –
Reduced VAT Rates:
Level of attention paid Increased 8% for essential goods (bread, milk, medicines),
by Tax Authority scrutiny
hospitality, and cultural services.
Central and Eastern European tax guide 2025 Forvis Mazars 38