Moldova

Corporate income tax (CIT)

Starting with the 2023 fiscal period:

• The income obtained from economic transactions performed with shareholders or other related parties at a price lower than lower market value will be adjusted for tax purposes to the market value.    
• The threshold value of fixed assets recognised for tax purposes has been increased to MDL 12,000.
• For entities that apply International Financial Reporting Standards (IFRS), the calculation and deduction of amortisation related to the right to use fixed assets that are the subject of an operational leasing contract is performed by the lessee.
• Large companies (except companies engaged in financial and insurance activities) can use the accelerated amortisation method for the first year in which the fixed asset is put into use.

• Enterprises classified as micro, small or medium, according to the criteria determined on the last day of the tax period according to the provisions of Law no. 179/2016, can pay the calculated corporate income tax until the twenty-fifth day of the month following that in which dividends were paid, including in the form of stocks or shares, from the profit obtained in the tax periods 2023-2025 inclusive. The amount of corporate income tax to be paid is determined by applying the pro rata between the amount of corporate income tax calculated for the tax period and the taxable income for the respective tax period.

• In the case of non-residents which carry out activities in Moldova through a permanent establishment, all properly documented expenses related to income obtained by the permanent establishment.

Payroll taxes

Starting 1 January 2021, mandatory social security contributions (SSC) due by the employer and employee are combined into a single 24% rate (with some exceptions) and are fully borne by the employer. The employee bears the single mandatory health insurance contribution of 9%.                                                                                         

New provisions regarding the calculation of the SSC apply as of 1 January 2023:

• For each full-time employee, the minimum monthly taxable base for the calculation of SSC cannot be lower than the national minimum monthly salary as determined under the law based on the actual hours worked.
• For part-time and reduced-work schedule employees, the SSC calculated by reference to the monthly taxable base cannot be lower than 25% of the SSC determined by reference to the national minimum monthly salary.

Value-added tax (VAT)

Starting 1 January 2021, the VAT rate for accommodation services, food, and beverages supplied by entities that provide public accommodation and catering services has been decreased from 15% to 12%.

Starting 15 April 2022, the e-book production and/or audio and electronic periodicals publications and/or audio, as well as editing services, services regarding copyright, and related rights, are VAT-exempted supply without deduction right.

Starting 1 May 2022, a taxable subject must provide to the buyer an electronic tax invoice (i.e. 'e-Factura') for VATable supplies of main petrol products (i.e. gasoline, diesel) performed on Moldovan territory.

The following main modifications related to VAT entered into force on 1 January 2023:    

• Companies registered as VAT payers that register transactions using the Automated Informational System (AIS) and/or issue tax receipts through machines with Electronic Sales Monitoring (ESM) have a right to the refund of VAT on purchased goods and services. The refund will be made in the amount of the excess VAT on purchases (including VAT on imports) over the amount of VAT on supplies for transactions registered as of 1 January 2023.

• The reverse charge mechanism for VAT on import of services has been implemented, so VAT payers are not required to pay VAT on such imports. The VAT amounts related to these transactions will be reflected as output VAT, and input VAT will be allowed for deduction. Non-VAT payers will be required to pay and declare VAT on the import of services.

• Supplies of electric motor scooters, ferrous and non-ferrous metal waste and residues, and industrial residues containing metals or alloys became taxable supplies.

Excise duties

The excise duties rates are gradually increased in line with Deep and Comprehensive Free Trade Agreement (DCFTA) provisions to which the Republic of Moldova is part.

Tax on immovable property

The maximum and specific rate for determining the real estate tax have been abolished.

The reporting and payment deadline for immovable property tax is 25 September of each year for property acquired by 31 August. For property acquired after 31 August, the reporting and payment deadline is  25 March of the tax period following the reporting one.

Taxpayers may no longer benefit from a 15% discount at the payment of the tax on the immovable property by 30 June.

Taxes on the natural resources

As of 1 January 2023, natural resources taxpayers have to submit the tax return and pay the taxes by the 25th day of the month following the end of the reporting quarter as follows:

• Water tax - paid to the local public administration authorities of the second level.
• Tax for extraction of useful minerals - 50% of the tax amount is paid to the first-level local budget and 50% to the second level of the local budget.
• Tax for the use of the subsoil - paid to the local public administration authorities of the second level

Withholding taxes (WHTs)

 The following changes came into effect on 1 January 2023:

• Banks, savings and loan associations, as well as issuers of corporate securities, withhold a final tax of 7 % from the interest paid to resident individuals.
• Companies withhold 12% from the interest income and 50% from the capital gains obtained by individuals from state securities.