​​​Amendments to tax legislation and other normative acts​

21 Jul 2025

In short

Law no. 187/2025 has been published, introducing substantial amendments to the tax legislation and other normative acts.

In detail

Income tax

Deduction of expenses related to entrepreneurial activity 

The reimbursement of expenses incurred by employees for visiting rural tourism reception structures in the Republic of Moldova, as well as expenses related to vacation vouchers, are allowed for deduction at up to 50% of the national average monthly salary, as forecast and approved by the Government of the Republic of Moldova for the given year, applicable for each employee.

Personal income tax exemptions

When determining the taxable annual income threshold of MDL 360,000 for the application of the personal exemption, resident individuals should also consider income derived from independent activities as well as activities related to the procurement of phytotechnical and/or horticultural products and/or plants.

Non-residents taxation

Income earned by non-resident individuals who do not engage in entrepreneurial activities on the territory of the Republic of Moldova, in the form of capital gains related to government securities and/or bonds issued by local public administration authorities, will not be subject to taxation in the Republic of Moldova.

​​Value added tax (VAT)​

The delivery of cars and other vehicles classified under specific tariff positions based on financial leasing contracts concluded before 1 January 2026 will not be subject to VAT.

Reforestation/afforestation services and forest rehabilitation under the National Forest Expansion and Rehabilitation Program 2023–2032 will be exempt from VAT with no deduction right.

Transfer pricing

Taxpayers only have to submit transfer pricing files upon request from the Moldovan State Tax Service, within 120 days as of the request, for transactions with a total value exceeding MDL 20 million. This provision is also applicable for the year 2024. Failure to submit the transfer pricing file for 2024 within the established deadline will not be considered a tax infringement.

The deadline for submitting the transfer pricing information has been adjusted, with taxpayers required to provide the information no later than the twenty-fifth day of the sixth month following the end of the tax period.

The method for determining the threshold and documenting transactions has been clarified. The new definition states that, for the purposes of determining the threshold and documenting transactions with related parties, advances given/received, exchange rate differences, and the revaluation of assets and liabilities recorded in the accounting records as a result of transactions with related parties are not considered, except for foreign exchange transactions. For determining the threshold for transactions related to leasing, credit and loans, only the interest provided for in art. 12, pt. 7)1 of the Tax Code calculated during the tax period is taken into account.

Controlled transactions subject to an advance pricing agreement are not included in the determination of thresholds and the documentation of transactions for transfer pricing purposes.

Taxpayers have been granted the right to submit corrected transfer pricing information, and the deadline for submitting the corrected transfer pricing file is within 30 days as of the date the Moldovan State Tax Service communicates its decision regarding transfer pricing adjustments.

Taxpayers have to calculate and report the single tax resulting from transfer pricing adjustments for transactions conducted throughout 2024 by submitting a report on the single tax for transactions with related parties to the Moldovan State Tax Service by 25 December 2025. As of 2026, the reporting of the single tax due to adjustments will be done by submitting a report by the twenty-fifth day of the sixth month following the end of the tax period.

​​​To remember​​

The provisions of Law no. 187/2025, through which amendments are made to tax and other normative acts, will enter into force on 18 July 2025, with some exceptions.

 

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Contact us

Daniel Anghel

Country Managing Partner, PwC Romania

Ruxandra Târlescu

Partner, Tax, Legal & People Services Leader, PwC Romania

Ilona Panurco

Legal Manager, PwC Moldova

Alina Timotin

Tax Manager, PwC Moldova

Anna Gîscă

Tax Manager, PwC Moldova

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