This refers to situations where an individual or a legal entity has found that the application by the State Tax Service of an agreement or convention for the avoidance or elimination of double taxation, to which Moldova is a party, has led or may lead to double taxation.
This and other amendments to the Tax Code (regarding direct taxes) have been approved by Parliament. Provisions are made for situations where two or more states claim the right to tax the same income or profits.
Then, one year later, from 1 January 2028, the concept of a controlled foreign company and the procedure for applying tax legislation to such companies will come into force.
Provision is made for the reallocation of such companies’ income, derived in low-tax jurisdictions, to the parent company located in a country with a higher tax rate. The parent company will then be obliged to tax this income in its country of residence.
Furthermore, from the date of Moldova’s accession to the EU, provisions on the taxation of interest, royalties and dividends between companies from EU countries, as well as rules for parent and subsidiary companies, will come into force. The changes have been drawn up as part of the partial transposition of an EU directive.
This story was translated with the assistance of artificial intelligence.
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