Moldova: Guidance on various direct and indirect tax issues; consultation on amendments to VAT refund requirements; changes to tax invoice requirements

Guidance from State Tax Service and proposed amendments and changes from Ministry of Finance

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March 3, 2025

The State Tax Service (STS) issued the following items of guidance on various direct and indirect tax issues:

  • Explanation on January 29, 2025, that dividends received by Moldovan businesses from entities in the Transnistria region, if not taxed there, are taxable in Moldova. Tax rates of 6% or 15% apply, depending on the year the dividends were received. The payer has no obligation to declare this income, but must withhold the tax. Any income not subject to withholding according to these rules must be declared and taxed locally.
  • Clarification on January 15, 2025, that advance payments received by an information technology (IT) park resident are not subject to the 7% unified tax. However, to enjoy the exemption, an IT park's resident's income from eligible activities must make up at least 70% of total sales on a monthly and yearly basis.
  • Confirmation that VAT payers are required to use the new form for value added tax (VAT) refund requests effective January 1, 2025. Payers must specify the VAT amount for refund, and tax periods and the relevant Tax Code article must be provided in the refund form.
  • Clarification on January 10, 2025, that unpaid property rent cannot be claimed as a tax-deductible expense if owed to a related party because expenses to related parties are nondeductible without proper evidence. A company failing to pay rent to a related party may not deduct the expense until payment and substantiation.

In addition, the Ministry of Finance on February 3, 2025, began consultations to amend VAT refund requirements. The proposed amendments include a requirement for the STS to generally determine the VAT refund method within three days of the request, a minimum two-year operation period, a limit on the interval between VAT refunds, and audit findings confirming VAT refund amounts.

The Ministry of Finance on December 30, 2024, also changed tax invoice requirements. Suppliers are no longer mandated to issue tax invoices when transferring goods, providing services, or granting free winnings within promotional campaigns to individuals, unless requested by the client. If an invoice is issued, it must include specific identification details of the client and be signed by the client for confirmation.
 

For further information, contact a KPMG tax professional in Moldova:

René Schöb | rschob@kpmg.com

Inga Tigai | ingatigai@kpmg.com

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