CHIȘINĂU, MOLDOVA · ACCOUNTING, PAYROLL, TAX ADVISORY
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Moldova proposes extending its 0% tax mechanism through 2029

The fiscal package approved by the Government on 8 September 2026 proposes extending the relief for undistributed profits through 2029 and raising the eligibility threshold from MDL 100 million to MDL 200 million.

What the 0% mechanism means

It defers corporate income tax payment, subject to eligibility. The 2027–2029 draft provides for payment when dividends are distributed or profits are used to cover losses from previous years.

An opportunity for foreign investors

A permanent establishment (PE) is part of the same legal entity as the foreign company. Transfers to that company are, in principle, not dividends. This suggests a potential tax opportunity requiring individual assessment: neither the PE’s eligibility nor the tax treatment of transfers can be assumed.

Legislative status and conditions

The sources consulted on 21 October 2026 do not confirm final adoption and publication of the law. The Official Gazette of 16 October published the Government’s opinion on amendments, not the law. The extension is therefore presented here as a proposal.

Application depends on the final legislation, eligibility and documentation of profits and transfers. VAT, payroll obligations and taxation in the foreign company’s country require separate analysis.

Plain Plan can help you compare a permanent establishment with a Moldovan LLC and choose a structure suited to your operations.

Sources and references

  1. Fiscal and customs policy for 2027: the Government proposal ↗Government of the Republic of Moldova · 8 September 2026 · Proposed extension through 2029 and MDL 200 million threshold. In Romanian.Accessed on
  2. Draft law: rules for deferring corporate income tax (PDF) ↗Government of the Republic of Moldova · Article III, point 21 · Proposed Article 87(1²) · PDF page 4. Draft text in Romanian.Accessed on
  3. Government opinion on amendments to the fiscal policy proposal ↗Ministry of Finance · 15 October 2026 · Legislative consideration before final adoption. In Romanian.Accessed on
  4. Official Gazette Nos. 512–515: publication of the opinion ↗Official Gazette of the Republic of Moldova · 16 October 2026 · Part II, item 144 · Opinion on Bill 326/2026, not an adopted law. In Romanian.Accessed on
  5. Permanent establishments and the 0% mechanism: Outsourced.md analysis ↗Outsourced.md · Plain Plan SRL · 9 September 2026 · English analysis underlying this news item; not legislation.Accessed on

This guide provides general orientation. A transaction’s treatment is established after reviewing its records and applicable rules.

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