The new mechanism is enshrined in the Tax Code. The amendments have been drawn up as part of the partial implementation of the European Union Directive. Under these provisions, if a company or an individual considers that the State Tax Service has misinterpreted an international agreement and this has given rise to a risk of double taxation (where two or more states claim the same income), the person or organisation will be able to lodge a complaint and request that the dispute be resolved.
The new provisions stipulate that a complaint may be lodged within three years of the first notification of the actions giving rise to the dispute, regardless of whether the affected party avails themselves of the legal remedies provided for under the domestic legislation of any of the contracting states concerned. The new rules will come into force on 1 January 2027.
At the same time, Moldova is working to prevent double taxation by concluding bilateral agreements (conventions) with other countries (for example, with Russia, Germany and France). These documents set out specific mechanisms for allocating the right to tax different types of income (dividends, interest, royalties), clarify how tax residency is determined, how the competent authorities of the countries exchange information, and how potential disputes are generally resolved.
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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