Moldova

Foreign tax relief

Individuals are allowed to credit their foreign income tax paid against their Moldovan tax liabilities (an official confirmation issued by the relevant foreign tax authority is required), but only within the limits of the tax rate that would be applicable in Moldova on tax due for the year concerned.

Tax treaties

The Moldovan tax law expressly provides that the DTTs prevail over national provisions. The only exception refers to cases where the domestic norms provide for more favourable tax rates (i.e. in such circumstances, the domestic rates apply). Thus, WHT might be reduced.

For DTT purposes, the non-resident has to present its certificate of fiscal residency prior to the payment of income. The certificate should meet certain criteria.

There are currently 50 DTTs concluded and in force that may provide for a more favourable tax regime. See the Withholding taxes section in the Corporate tax summary for a list of countries with which Moldova has a DTT.

Moldovan tax authorities and taxpayers have to use Commentaries to the Organisation for Economic Co-operation and Development (OECD) Model Tax Convention to clarify tax issues related to the applicability of DTTs.