Svetlana Slobodianu
Most of the questions—at least in the media—have centered on the proposed changes to personal income tax related to income from the sale of housing, gifts, and interest on bank deposits.
Finance Minister Andrian Gavrilita recently provided some clarification on these proposals, assuring the public that they would be refined.
However, there are just as many questions regarding corporate taxation. Representatives of the business community have prepared their feedback on the 2027 tax policy, in which, as the head of one business association emphasized, “there are more questions than answers.”
The changes proposed by the Ministry of Finance cover virtually all major taxes and regimes: income tax, VAT, excise taxes, the regime for independent entrepreneurs (freelancers), and others.
How to Tax Unallowable Business Expenses
For example, in terms of corporate taxation, one of the most controversial proposals is to include not only distributed profits and dividends in the tax base, but also so-called non-deductible business expenses.
Svetlana Slobodeanu, an auditor, internationally certified practicing accountant, and Doctor of Economics, offers her assessment of this initiative.
“This is one of the most problematic changes. In practice, this proposal gives rise to many legally unresolved situations,” she says. “For example, what about ‘adjustable’ expenses that are reversed over time—depreciation of fixed assets, provisions, and debts that were previously written off but subsequently recovered?”
Or how will expenses be taxed during a company reorganization? How should one proceed in cases where a company with accumulated losses merges with an enterprise that has retained earnings? And what happens to profits from periods prior to 2027, which were taxed under the rules in effect at that time, but for which dividends are paid after January 1, 2027?
“These aren’t rhetorical questions, but real-life situations faced by every other business in the country,” the expert concludes. “This provision is half-baked, creating legal uncertainty and tax disputes.”
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