In this case we are talking about taxpayers registering and/or performing transactions with affiliated persons, the total value of which during the tax period, calculated by summing up the value, excluding VAT, is equal to or exceeds MDL 50 million. If the amount of transactions is from 20 million to 50 million lei, the submission of such information is obligatory only at the request of the STS. The agency also informs that explanatory information on transfer pricing is available in a special section on the STS website. There you can download all the necessary instructions and samples of reports to be filled in.
This is the first procedure since the transfer pricing system regulations have been in force in Moldova. It showed that today there are still more questions than answers. The most important question that taxpayers continue to ask is where to find the list of prices for comparative analysis, according to which to prepare such information? Not all companies can afford to purchase them or engage specialized companies to prepare it. In addition, it would be more correct to prescribe in the legislation an approximate sufficient document to which enterprises could refer.
According to experts, both the form of information and sending it by e-mail, as required by the legislation, is not the most convenient way of submitting reports. A company may have many files – from six to infinity. This is difficult for taxpayers in terms of their transfer, and the tax authorities will then process these files will not be easier. As experts note, residents do not always want to specify their fiscal code, which is necessary for the preparation of files. This can become a problem for the reporting company.
“We believe that it was possible to provide for the filing of such information in the form of a single document on a standard platform for filing reports,” says an LP interlocutor on condition of anonymity. – The option chosen by the developers implies the need to take into account a lot of points from the field of law, not accounting. The procedure for preparing and submitting information has become too complicated. The only good thing is that sanctions will not be applied in the first two years – until 2027 – after the transfer pricing provisions come into force”.
Companies will have to submit their first transfer price dossiers by June 30 this year.
