Page 37 - Mazars Central and Eastern European tax guide 2023

Moldova VAT-exempt activities include medical services, financial assimilated to employment) or independent activities
(freelancers). Annual personal exemption is applied to the
and banking services, insurance and reinsurance, sale
and rental of land and residential premises (houses and amount of EUR 1,350.
apartments), certain types of educational and training Social Security Contribution (24% – employer part) and
activities, and other activities of public interest.
Health Insurance Contribution (9% – employee part).
TAXACO SRL Other indirect taxes applicable include excise and Dependent activities are subject to HIC at the employee
str. Calea Iesilor 8/1,3 fl, of. 9a environmental tax. (9%) and SCC at the employer level (24%).
rd
MD2069, Chisinau,
Moldova Personal income tax / Social security system Meal vouchers are taxed with SCC at a rate of 24%.
Phone: +373 22 211 819 A 12% flat rate tax is applicable to revenues obtained The minimum monthly gross wage for the period starting
www.taxaco.md
from dependent activities (e.g., employment or activities 1 January 2023 in real sector is MDL 4,000 per month.

Average wage
Wage related taxes in Moldova Minimum wage in private sector
Corporate taxes and other direct taxes • 4% on total revenue Exchange rate MDL/EUR 19.84 in EUR in MDL in EUR in MDL
A microenterprise may opt for the CIT regime if it fulfils the
General CIT is 12%. To compute the taxable profit, following: 202 4,000 590 11,700
the accounting profit is adjusted upwards (with non- • they become a VAT payer; Total wage cost 250 124.00% 731 124.00%
deductible expenses) or downwards (with non-taxable • more than 50% of the revenue is generated by VAT
revenues). Tax losses are carried forward for 5 years. Vocational training contribution – –
exempted supplies Social Contribution tax 48 24.00% 142 24.00%
For CY 2023-2025, special tax relief is being applied for Health Insurance Contribution - –
limited liability companies and joint stock companies A special tax regime for residents of IT Parks (Law
that represent SME (small and medium enterprises) – CIT No 77/2016), 7% on monthly sales income but no less Gross salary 202 100.00% 590 100.00%
calculated for CY 2023-2025 is paid to the State Budget than MDL 3,510 per employee per month (Unique Personal income tax* 8 12.00% 51 12.00%
only in the case of dividend payments. This tax relief is not Tax). This regime is available for the period until 2027 Employees' Social contributions – –
applied to financial and insurance companies. inclusively. 70% of the sales generated by a resident Employees' Health contributions 18 9.00% 53 9.00%
should correspond to the list of IT services approved
Moldova has a treaty network consisting of 50 double tax by law (including 3D programming and R&D) This unique Net salary 175 86.83% 486 82.39%
treaties. The WHT rate on dividends is 6%, while for Interest tax includes all payroll taxes as well as social insurance
and royalties it is 12%. *Personal tax excemption in the amount MDL 27,000 is applied annually (27,000/12 monthly).
contributions and compulsory state health insurance
Capital gains from the sale of shares and other capital and all local taxes. Consequently, a resident of an IT Park
assets are taxable for non-residents – legal persons 12% is liable for unique tax, withholding tax and VAT.
and for individuals, only 50% of the capital gain is taxed
at the rate of 12%. The relevant double tax treaties are VAT and other indirect taxes
applicable.
The general rate is 20%. Reduced rates are 8% (e.g.,
A compulsory micro company scheme is applicable for bread, milk and dairy products, medicines, natural
non-VAT payor companies with revenues below MDL gas, agricultural products, etc.) and 12% (e.g., hotel
1,200,000 (approx. EUR 58,500) for a calendar year: accommodation, restaurant services).
Transfer pricing in Moldova VAT options in

Since 2024 for operations Moldova Applicable / limits
Arm's length principle ü that cumulatively exceeds
EUR 1,000,000. Distance selling ü
Documentation liability ü Since 2024 Call-off stock No
APA No VAT group registration No
Country-by-Country Cash accounting – yearly
liability No amount in EUR (approx.) No
Master file-local file
(OECD BEPS 13) ü Since 2024 AEO, for goods is paid no later than when
applicable Import VAT deferment custom clearance is performed. Sale
of collaterals and property of bankrupt
Penalty entities.
lack of documentation ü EUR 7500–25000 Local reverse charge Sale of collaterals and property
of bankrupt entities.
tax shortage No – Option for taxation
Min.
Related parties of Direct or indirect control. letting of real estate Land and residential premises Iuri Cicibaba
25% are exempt. Managing Partner
Safe harbours No supply of used real estate VAT is not calculated for individuals on Mobile: +373 69 325 938
real estate transactions.
Level of attention paid by Tax VAT registration approx. EUR 58,800 E-mail: icicibaba@taxaco.biz
Authority N/A threshold

36 Mazars Central and Eastern European tax guide 2023 Central and Eastern European tax guide 2023 Mazars 37