This refers to cases where taxpayers consider that the State Tax Service’s interpretation or application of a treaty or convention for the avoidance or elimination of double taxation, to which Moldova is a party, has led or may lead to double taxation.
As previously reported by Logos Press, the draft law amending the Tax Code (in respect of direct taxes) was approved yesterday by the government. The aim of incorporating a mechanism for resolving tax disputes into the Tax Code is to prevent the transfer of profits to jurisdictions with lower tax rates.
Furthermore, from 1 January 2028, it is proposed to introduce into the Tax Code the concept of a controlled foreign company (CFC) and the procedure for applying tax legislation in relation to such companies.
The draft provides for the reallocation of income from controlled foreign companies from low-tax jurisdictions to the country of the parent company, where the tax rate is higher. The parent company will be obliged to tax this income in its country of tax residence.
The remaining proposals included in the draft will come into force on the date of Moldova’s accession to the European Union. The draft, which has been approved by the Cabinet of Ministers, is yet to be considered and approved by Parliament.
This story was translated with the assistance of artificial intelligence.The translation was also reviewed by the Logos Press editorial team.
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