Moldova

Foreign tax credit

Income tax paid in any foreign country, if this income is subject to taxation in Moldova, is allowed for tax credit, provided that the taxpayer submits a document that justifies payment (withholding) of the income tax outside of Moldova, certified by the competent body of the respective foreign country, with its translation into the state language.

The amount of tax credit for any taxable year should not exceed the amount that would have been estimated at the rate applicable in Moldova with regard to this income.

A tax paid in a foreign country should be creditable for the year in which the income is taxable in Moldova.

Free entrepreneurial zones (FEZs)

FEZs are territories where domestic and foreign investors can carry out entrepreneurial activities on preferential terms (i.e. favourable tax, customs, visa, and other regimes). There are currently seven FEZs in Moldova.

The following types of activities may be carried out in an FEZ:

• Production of goods preferentially for export, excluding alcohol and alcoholic products.
• Sorting, packing, marking, and other similar operations of goods transiting the customs territory of Moldova.
• External commercial activities.
• Other supportive activities.

There is also an international free port (Giurgiulesti International Free Port) and airport (Marculesti International Free Airport) with status similar to FEZs that can benefit from specific tax and customs incentives.

FEZ incentives

The following CIT incentives for FEZ investors are in place:

• Entities that are established in the FEZ and export goods and services from the FEZ outside the customs territory of Moldova or deliver the produced goods to other FEZ residents for goods to be exported are entitled to apply only 50% of applicable CIT rate on such gains. For other cases, the CIT rate is 75% of the established one.
• The income obtained from export of goods (services) originating from the FEZ outside the customs territory of Moldova or from supply of the produced goods to other FEZ residents for goods to be exported is CIT exempted for a period of one year, provided that the FEZ residents invested in the fixed assets of their enterprises and/or in development of the infrastructure of the FEZ capital equivalent to at least 1 million United States dollars (USD).
• The income obtained from export of goods (services) originating from the FEZ outside the customs territory of Moldova or from supply of the produced goods to other FEZ residents for goods to be exported is CIT exempted for a period of three years, provided that the FEZ residents invested in the fixed assets of their enterprises and/or in development of the infrastructure of the FEZ capital equivalent to at least USD 3 million.
• The income obtained from export of goods (services) originating from the FEZ outside the customs territory of Moldova or from supply of the produced goods to other FEZ residents for goods to be exported is CIT exempted for a period of five years, provided that the FEZ residents invested in the fixed assets of their enterprises and/or in development of the infrastructure of the FEZ capital equivalent to at least USD 5 million.
• The income obtained from export of goods (services) originating from the FEZ outside the customs territory of Moldova or from supply of the produced goods to other FEZ residents for goods to be exported is CIT exempted for an additional period of time, provided that the FEZ residents performed additional investments in the fixed assets of their enterprises and/or in development of the infrastructure of the FEZ capital (under certain conditions).

From a VAT standpoint, goods and services supplied in the FEZ from abroad, from the FEZ outside the customs territory of Moldova, in the FEZ from other areas of Moldova, and those supplied to residents of other FEZs are VAT exempted with deduction right (with some exceptions).

According to the customs provisions, goods are introduced into the FEZ with no VAT or customs duty and are not subject to economic policy measures, according to specific criteria. However, certain taxes in specific situations might be incurred by residents of the FEZ. Investors in the FEZ are guaranteed and protected from changes in legislation for a general period of up to ten years, while under certain conditions this period may be extended to 20 years.

Law on information technology (IT) parks

Starting 2017, the law on IT parks entered into force. The law provides for certain tax incentives for the IT parks’ residents.

Under this law, residents of the parks could be legal persons or individuals registered in the Republic of Moldova as conducting entrepreneurial activity that carry out as their principal activity one or more of the following activities:

• Custom software activities (client-oriented software).
• Computer games editing activities.
• Editing activities of other software products.
• Management activities (management and exploitation) of calculation means.
• Data processing, webpage administration, and other related activities.
• Web portal activities.
• IT consulting activities.
• Other IT services related activities.
• Other forms of educations, limited to computer instruction.
• Research and development in other natural sciences and engineering, based on the use of specialised high-performance equipment.
• Research and development in biotechnology.
• Manufacture of electronic components.
• Cinematographic, video and television program post-production activities, based on the use of specialised high-performance equipment.
• Specialised design activities, based on the use of specialised high-performance equipment.

Starting 12 February 2024, the following new types of activity eligible for IT park were introduced:

• Activities of call centres, including those based on any technology or communication channel with the customer (contact centre), exclusively for export.
• Labour force supply services, provided exclusively for export.

The residents of the IT parks are subject to a single tax that includes:

• CIT.
• PIT.
• Mandatory social security contributions.
• Mandatory health insurance contributions.
• Local taxes.
• Tax on immovable property.
• Road tax applied to vehicles registered in Moldova.

For the rest of the taxes, standard applicable tax treatment shall be applied.

In this context, the principal activity is that which generates 70% of a park resident’s sales revenue.

The single tax of 7% of sales revenue, but not less than the minimum amount due per employee, is to be calculated and paid monthly by each park resident. The minimum amount of single tax per employee is set at 30% of the national average forecasted salary for that year (e.g. MDL 13,700 for 2024).