The standard corporate tax (‘CIT’) rate for companies is 12%. Effective 1 January 2020, capital gains are fully taxable as ordinary income. Previously, only 20% of the net capital gains were subject to income tax.

However, a number of other rates apply as follows:

A corporate income tax rate of 15% applies to any excess income resulting from a re-assessment by the Moldovan Tax Authority (‘MTA’);
Small and medium enterprises (SMEs) that are not registered for VAT may opt to be taxed at the rate of 4% on turnover. However, effective 1 January 2024, if during any tax quarter, any shareholder of an SME holds 25% or more of the shares or voting rights in more than three SMEs, then one of the SMEs must change to the general tax regime from the respective tax quarter, and the standard corporate tax rate would apply to that SME;
Effective 1 January 2024, companies carrying on activities in the field of commercializing ferrous and non-ferrous metal waste are taxed at a unified tax rate of 7% on the sales income; and
Certain companies are subject to lower corporate income tax rates pursuant to incentive regimes (see Sec. 10.).

A withholding tax at the rate of 6% (15% until 2011) is applicable on dividend income received by a resident company from another resident company.

Pillar 2 Global Minimum Tax

On 20 December 2021, the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (BEPS) released model rules called Global Anti-Base Erosion (GloBE). These rules basically provide for a coordinated system of taxation that is intended to reform international tax rules and ensure that large multinational enterprise (MNE) groups pay a minimum level of tax on the income arising in each of the jurisdictions where they operate.

Essentially, the Pillar Two rules provide for the implementation of an Income Inclusion Rule (IIR) and an Undertaxed Profits Rule (UTPR) with respect to in-scope MNEs, being those with annual consolidated revenues of EUR 750 million or more in at least two of the four fiscal years immediately preceding the tested fiscal year. Under the Pillar Two rules, taxpayers in the scope of the rules are required to calculate their effective tax rate for each jurisdiction where they operate and pay a Top-up tax for the difference between their effective tax rate per jurisdiction and the 15% minimum rate. Any resulting Top-up tax is generally charged in the jurisdiction of the ultimate parent of the MNE. Further, the Pillar Two rules also allow jurisdictions to opt for the adoption of a Qualified Domestic Minimum Top-up Tax (QDMTT) based on the GloBE mechanics, which will eliminate any liability under GloBE.

The following entities are out of the scope of the GMT rules:

Government entities, international organizations, non-profit organizations, and pension funds;
Investment funds and real estate investment vehicles but only when they are the ultimate parent entity of an MNE Group; and
Entities directly or indirectly owned by the above-mentioned entities.

On 28 May 2024, Moldova joined the OECD’s Inclusive Framework, all members of which have committed to implement the BEPS minimum standards, as well as the two-pillar solution to address the tax challenges arising from the digitalisation of the economy. Hence, it is expected that Moldova will also participate in the implementation of the two-pillar solution, including the Pillar Two Global Minimum Tax.

Tax on Mineral Exploitation

The tax on useful mineral exploitation is levied as a percentage of the cost of the useful minerals extracted. The following are the applicable tax rates:

S.No.	Nature of minerals	The tax as a percentage of the cost of the minerals extracted
1.	Metalliferous raw materials and non-metallic raw materials for industry (granite, gabronorite, diatoms, diatoms, tripoli, limestone, bentonite clays, hard to fuse, refractory and molding, raw materials for the manufacture of quartz and silicon glass)	7
2.	Non-metallic building materials (raw materials for cement, chalk, cladding stone, cut stone, crude stone, broken stone, construction sand, mixtures of gravel with sand, pebbles, gravel, raw material for ceramite, clay for brick, etc.)	6
3.	Oil	20
4.	Gas	20
5.	Gypsum, sandstone	10

Alternative Minimum Tax

There is no minimum tax.

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