Moldova broadens deferred corporate tax option for 2027–29 profits

The option depends on size tests

Amended Tax Code Article 87(1²) covers a taxpayer with no more than 249 employees and either annual turnover of no more than MDL 200 million or total assets of no more than MDL 200 million. An eligible taxpayer may elect, through its income-tax return, to defer the tax calculated on profits for tax years 2027–2029. The rule is a timing option, not an exemption from corporate income tax.^[1][2][3]

Distribution or loss use triggers payment

Tax on an elected profit pool becomes payable by the 25th day of the month following the month in which the company pays dividends from that profit or uses it to cover prior-year losses. The amount is calculated by reference to the portion distributed or applied against losses. Companies will therefore need a year-by-year ledger linking elected profits, dividend decisions, loss coverage and the resulting payment month.^[2][3]

Several categories are excluded

The option does not apply to individual enterprises, farmers’ households, residents of free economic zones or the Giurgiulești and Mărculești free-port regimes, IT park residents, specified special-regime taxpayers, financial and insurance businesses, or certain larger retailers. Eligibility should be tested against the enacted entity and activity exclusions rather than inferred from employee count alone. The separate temporary 18 per cent rate for financial and insurance companies is already covered by a distinct Straxiom article and is not presented here as part of this deferral.^[2][3]

Prepare the return election and trigger controls

Groups with Moldovan companies should map employee, turnover and asset figures, confirm excluded status, identify the 2027–2029 profit pools for which an election may be made and design controls for later dividends and loss coverage. The general commencement rule is 1 January 2027. The reviewed law establishes the return-based election and payment trigger, but does not resolve every interaction with reorganisations, accounting adjustments or later corrections; those points require current authority before implementation.^[2][3]