Moldova raises 2027 corporate tax rate for financial and insurance companies to 18%

A one-year sector rate

Article IV of Law No. 247 adds paragraph (38) to Article 24 of Law No. 1164/1997, which implements Titles I and II of Moldova’s Tax Code. The new paragraph derogates from Article 15(b) of Tax Code No. 1163/1997, under which legal persons are ordinarily taxed at 12% of taxable income. For fiscal period 2027, legal persons conducting financial and insurance activities referred to in Section K of Moldova’s economic-activity classification must instead apply an 18% rate to taxable income. The measure therefore raises the statutory rate by six percentage points for the specified period; the enacted text does not make the sector increase permanent.^[1][2]

Classification needs careful review

The scope is entity- and activity-specific. It is not a general surcharge on every group with a Moldovan presence, and the law states the tax base as taxable income rather than turnover. Groups should also note a drafting issue in the enacted package: Article IV names financial and insurance activities but refers to Section K, while another amendment in the same law changes an existing Tax Code reference for those activities from Section K to Section L of CAEM Rev.2.1. The precise classification reference should therefore be confirmed before treating an entity as inside or outside the 18% rule.^[1]

What multinational groups should do

Banking, insurance and other financial groups with Moldovan legal entities should identify each entity’s registered and actual CAEM activities, model the 2027 current-tax effect and reflect the enacted rate in forecasts and tax provisioning where the statutory scope is met. Groups should keep classification evidence with their 2027 tax workpapers and monitor for an official correction or application guidance on the Section K reference. The law’s general commencement rule is 1 January 2027, and Article IV is not listed among the exceptions that take effect on publication or on another date.^[1]

Separate package measures

Law No. 247 is a broad tax and customs package containing other corporate, dividend, VAT and compliance changes. Those measures require their own whole-package review and should not be inferred from this focused article. In particular, this article does not state that the 18% rule changes an existing return, payment or filing deadline.^[1]