Moldova: Guidance on income tax treatment of SMEs upon merger
Guidance confirms that a merger by absorption does not trigger income tax liability under the SME zero-income tax regime.
The State Tax Service on June 18, 2026, clarified the tax treatment applicable to small and medium-sized enterprises (SMEs) operating under Moldova’s zero-income tax regime for 2023-2026 when a merger by absorption occurs.
The guidance provides that a merger by absorption does not give rise to income tax obligations under the SME zero-income tax regime. According to the State Tax Service, income tax becomes due only when dividends are distributed.
The clarification further states that a reorganization through absorption results in the transfer of rights and obligations to the absorbing entity and does not constitute a dividend distribution. As a result, the merger transaction itself does not trigger income tax under the SME regime.
For more information, contact a KPMG tax professional in Moldova:
Inga Tigai | ingatigai@kpmg.com