Md Corporate Income Tax

---
name: md-corporate-income-tax
description: "Compute Moldova resident-company corporate income tax for 2026, including the ordinary taxable-profit reconciliation and the separate eligible non-VAT SME accounting-income regime. Use for regime and legal-category selection, business expenses, employee benefits, financing, depreciation, losses, foreign-tax credits, instalments, distributions and withholding. Distinguish company tax from shareholder withholding and the dividend-linked payment-deferral option. Establish actual tax-period, VAT, ownership, activity, profit-origin and payment facts before calculating. This source-cited draft preserves the earlier Guide subjects, states exact remaining ordinary and specialist gaps, and has a bounded source-review record linked under Sources. It does not claim accountant attestation or comprehensive coverage."
license: "AGPL-3.0-or-later (code) / OpenAccountants Guide License v1.0 (content)"
metadata:
  source: openaccountants
  openaccountants_url: "https://www.openaccountants.com/skills/md-corporate-income-tax"
  jurisdiction: "MD"
  tax_year: "2026"
  last_updated: "2026-10-31"
---

# Moldova corporate income tax, 2026 v0.16

## Who this applies to

Compute ordinary resident-company profit tax and the separate eligible non-VAT SME income regime for 2026. Establish the taxpayer, elected regime and applicable period before calculating. Resident business entities include income from Moldova and abroad, less the deductions and exemptions they actually qualify for. Legal persons use accrual accounting. This is a source-cited draft, without accountant attestation or comprehensive country coverage. [Fiscal Code arts. 13–14, 44][code].

A company is resident if its activity is organised or managed in Moldova, or Moldova is its principal place of activity. The ordinary income-tax period is the calendar year; a newly created business starts at registration. A lawful noncalendar accounting period has Code art. 12^1(4)–(6)'s separate eligibility, notification and transition requirements; liquidation, reorganisation and IT-park entry/exit have their own short-period rules. Do not use the excise article 121 in place of income-tax article 12^1. [Code arts. 5(5)(b), 12^1][code].

The 7% rate belongs to the statutory **gospodărie țărănească (de fermier)** category. It is not a rate for every agricultural company. Individual entrepreneurs use the 12% annual taxable-income rule and their own personal/entity procedures; the corporate Guide does not replace the [individual-income Guide](moldova-income-tax.md). IT-park, free-zone, financial-sector and other special regimes require their own legal eligibility tests. Use [transfer pricing](md-transfer-pricing.md), [cross-border](md-cross-border.md), [VAT](moldova-vat.md), [payroll](moldova-payroll.md) and [social contributions](moldova-social-contributions.md) for the connected subjects, with each file's stated currency and gaps. [Arts. 15, 49, 54^1, 87(1^1)][code].

## Rates, bands and thresholds

Amounts are MDL unless stated otherwise. A percentage does not establish which regime applies.

| Item | 2026 rule | Primary authority |
|---|---|---|
| Ordinary company profit tax | 12% of taxable income | [Art. 15(b)](https://www.legis.md/cautare/getResults?doc_id=157050&lang=ro) |
| Statutory peasant-farm category | 7% of taxable income | [Art. 15(c)](https://www.legis.md/cautare/getResults?doc_id=157050&lang=ro) |
| Individual entrepreneur | 12% of annual taxable income | [Art. 15(a)](https://www.legis.md/cautare/getResults?doc_id=157050&lang=ro) |
| Income estimated under arts. 225 or 225^1 | 15% of the excess of the estimated income over the business's booked gross income; this is not the ordinary company rate | [Art. 15(d)](https://www.legis.md/cautare/getResults?doc_id=157050&lang=ro) |
| Eligible non-VAT SME regime | 4% of the defined accounting-income base, not ordinary taxable profit | [Arts. 54^2–54^3](https://www.legis.md/cautare/getResults?doc_id=157050&lang=ro) |
| SME election/mandatory-general threshold in art. 54^1(3)(a), (3^1) | 1.5 million in the text operative from 1 January through 26 March; 1.7 million from 27 March 2026. These tests use the specified previous-year supply income and conditions | [January Code](https://www.legis.md/cautare/getResults?doc_id=149766&lang=ro); [Law 41/2026 art. I(1), X(1)](https://www.legis.md/cautare/getResults?doc_id=153667&lang=ro); [27 March Code](https://www.legis.md/cautare/getResults?doc_id=153668&lang=ro) |
| Business/management consultancy exclusion from SME regime | Prior-year CAEM 70.22 service income above 60% of sales income | [Art. 54^1(1)](https://www.legis.md/cautare/getResults?doc_id=157050&lang=ro) |
| SME shareholding interaction | A holder above 25% in more than 3 SMEs triggers selection of the entity/entities moving to general taxation from the relevant quarter | [Art. 54^1(3^2)](https://www.legis.md/cautare/getResults?doc_id=157050&lang=ro) |
| Basic depreciable tangible asset test | Business-use balance-sheet property with useful life above 1 year and value above 12,000 | [Art. 26^1(2)](https://www.legis.md/cautare/getResults?doc_id=157050&lang=ro) |
| Ordinary tax loss carryforward | Following 5 tax periods; maintain origin order and remaining eligible balances | [Art. 32](https://www.legis.md/cautare/getResults?doc_id=157050&lang=ro) |
| Resident-individual dividend withholding | 6%; 15% for dividends from undistributed 2008–2011 profits | [Art. 90^1(3^1)](https://www.legis.md/cautare/getResults?doc_id=157050&lang=ro) |
| Nonresident dividend withholding | 6% ordinary domestic rate; 15% for the specified historic-profit/capital cases | [Art. 91(1)](https://www.legis.md/cautare/getResults?doc_id=157050&lang=ro) |
| Other covered nonresident-source payments | 12%, subject to the actual art. 71 category, statutory exclusions and applicable treaty | [Art. 91](https://www.legis.md/cautare/getResults?doc_id=157050&lang=ro) |

Law 41's SME amendment took effect on publication, 27 March. Its separate medical-device VAT amendment took effect on 1 May. Do not use the latter date for the SME threshold or confuse the SME test with VAT registration. The change is a regime-eligibility/election rule, not a daily apportionment of the 4% rate. [Law 41 arts. I(1), I(4), X][amend].

## The base

1. **Choose and document the regime.** Article 54^1 excludes VAT-registered taxpayers, peasant farms, individual entrepreneurs and the specified consultancy-heavy businesses from the SME class. For the election cases, test prior 31 December income from exempt-without-credit supplies alone or together with taxable supplies, the applicable threshold and the requirement that exempt-without-credit supplies exceed 50% of total supplies. No-prior-income and newly registered entities have separate election routes. Record the choice in accounting policy by 25 April for the first two routes, or by the 25th of the month after the registration quarter for new entities. Test the shareholding/number-of-SMEs limit. VAT registration moves the taxpayer to general taxation from registration; cancellation uses the art. 113(4) date. Preserve each regime's actual tax period. [Arts. 54^1–54^1/1][code].
2. **Reconcile ordinary profit tax.** Start with accounting revenue and expenses, not bank deposits. Include the taxable art. 18 receipts, including business receipts, rent, interest, royalties, covered debt releases and non-exempt subsidies/penal receipts. Remove only income demonstrably exempt under art. 20 or another controlling rule. Resident-company dividends received from another resident company have art. 20(z^19)'s exemption except the specified undistributed 2008–2011 profits. Recovery/reversal of an expense or provision never deducted has art. 20(z^17)'s rule, with its exception for provisions created in the stated 2023–2026 deferral periods. Do not exempt every grant, compensation or revaluation without its precise statutory category. Reconcile timing, unpaid related-party amounts and prior-year returns/discounts under art. 44. Add back income tax, statutory fines/penalties, private or exempt-income expenditure, unsupported related payments and other disallowed costs. Do not deduct a capital-asset purchase as an ordinary expense when depreciation rules apply. [Arts. 18, 20, 24, 30, 44][code].
3. **Apply expense-specific limits.** Ordinary necessary business expenses qualify under art. 24(1). Mixed business/private costs require its actual greater-business-than-private test and only the directly business portion. Travel, representation and business insurance have Government limits; do not assume the accounting amount qualifies. One-car restrictions apply to the specified occupation groups 112/121. Related-party losses need the arm's-length exception or other stated exception. Undocumented ordinary expenses have the 0.2%-of-taxable-income route; business-card purchases have a separate rule. Patent-holder/independent-retailer payments have their own restriction. Membership/subscription and qualifying union allocations have the separate 0.15%-of-payroll or two-forecast-average-salaries limit; the exact applicable alternative and recipient must be documented. [Art. 24(1)–(11)][code].
4. **Check new service-entrepreneur payments.** The art. 24(11^1) route covers the specified businesses with at most 9 employees and turnover or assets up to 18 million, subject to its 10%-of-annual-payroll payment limit, or the separate main-activity route above 70% for CAEM 59.1, 90.01, 90.02, 93.11 or 93.12. Verify the exact route rather than deducting every freelancer invoice. Employment reclassification and the recipient's separate single-tax regime must also be checked in the payroll/individual work. [Art. 24(11^1)][code]; [Finance Ministry 2026 explanation][changes].
5. **Reconcile employee-related expenditure.** Article 24(19^3) provides: annual in-kind gifts/vouchers up to 10% of the forecast monthly average salary per employee; specified training/team-building up to 5% of the defined payroll fund after excluding the stated management groups; sport subscriptions and qualifying rural-tourism/vacation-voucher costs together up to 50% of the forecast average salary per employee; medical services up to one forecast average salary per employee. Article 24(20) separately covers qualifying voluntary medical-insurance premiums up to one forecast average salary. The 2026 forecast is 17,400, giving 1,740, 8,700 and 17,400 for those respective per-employee caps. Taxed compensation above those limits must be tested under art. 24(19^2), not automatically disallowed or treated as exempt remuneration. Childcare has its separate 2,500-per-month-per-child limit for children under 3. Preserve the actual provider, benefit, cumulative-period and payroll facts. [Art. 24(19)–(20), (26)][code]; [CNAS 2026 instructions, point 12.1, citing Government Decision 773/2025][average].
6. **Financing, depreciation and other deductions.** For loans from the specified non-financial individuals/entities, compare the actual contractual interest with the BNM weighted banking rate for the matching currency and term, up to or above 12 months. Keep that limit distinct from transfer pricing. Maintain each tangible asset separately; ordinary straight-line depreciation starts the month after commissioning, using the Government useful life. Financial versus operating leasing determines the depreciating party, with the stated IFRS right-of-use exception. For qualifying repairs to rented/leased assets outside the ownership test, the ordinary limit is 15% of accrued rent/operating-lease/concession consideration; international aircraft have the separate 100% operating-lease cap, and qualifying own taxi vehicles have the stated full-repair deduction. Free assets are not depreciated unless their value entered taxable income; non-taxable partial financing limits the depreciable part, subject to the statutory post-investment subsidy exception. The non-financial-sector accelerated option permits at most 50% of entry cost in the first year, followed by remaining value over remaining useful life. Financial/operating leases, IFRS right-of-use assets, rented-asset repairs, grants and disposals each have separate rules. Limited-life intangibles amortise straight-line. Ordinary provisions and revaluation/impairment do not become deductible merely because booked; a legally established business bad debt has its own rule. [Arts. 25, 26^1, 28, 31][code].
7. **Losses and donations.** Keep a loss ledger by origin year, the five following periods, amounts already used and statutory ordering. Apply art. 32's remaining-balance rules; do not invent an indefinite carryforward or automatically deduct an expired amount. Qualifying charitable/sponsorship donations have the 5%-of-taxable-income limit and eligible-recipient/document requirements; statutory food-donation treatment is separate. The ordinary cash-donation cap is reconciled to approved VEN12 row 040 below; noncash/food and other special cases require their own applicable method. [Arts. 32, 36][code].
8. **Compute the SME base separately.** Use financial-accounting income for the SME period. Subtract current returns/discounts in the period they occur, including returns of prior-period sales. Exclude art. 20 income and income from exchange-rate or sum differences. Do not deduct ordinary operating expenses or use the ordinary 12% profit-base calculation. Apply 4%. Keep the short periods on entering/leaving VAT registration separate. [Arts. 54^1/1–54^4][code].
9. **Settle the actual liability.** For ordinary profit tax, apply the legal rate to the positive reconciled taxable income after eligible losses. Match qualifying foreign-tax credit to the same taxed foreign income and period, capped at Moldova's tax on that income. Credit evidenced instalments and applicable advance payments, avoiding double credit. The dividend-linked payment deferral below changes payment timing; it does not make all retained profit exempt. [Arts. 15–16, 32, 81–84, 87][code].

Article 24 also has specific stock-loss, environmental, infrastructure-transfer, audit/sector, stipend and liquidation rules. Their full special procedures are not certified by this draft. The ordinary Government procedures below resolve the identified representation, business-insurance, transport/food, development and donation-documentation gaps; the travel/asset procedures below are sourced; remaining annex applications, capped-base and actual-return implementation gaps stay explicit. Do not classify a payment from a vendor name or an assumed expense percentage.

### Company disposals and the individual capital-gain boundary

For an ordinary resident company, recognise the business disposal income and the admissible tax cost under the applicable company rules. **Do not remove half of a company’s share-disposal gain under art. 40(7).** Article 37 limits that capital-gains chapter to resident/nonresident **individuals who do not carry on business**; article 18(e)'s reference to art. 40(7) does not expand that taxpayer scope. The company's ordinary worldwide business-income and deduction rules remain arts. 14(1)(a), 18(a)/(o) and 24; depreciable property follows its separate tax-undepreciated-value method below. [Code arts. 14, 18, 24, 37–40][code].

Keep the nonresident rules distinct as well. Article 71(1)(c) refers to art. 40(7) for the specified nonbusiness **individual** gains; article 71(1)(d) expressly refers to art. 40(1)–(4), excluding paragraph (7), for a nonresident **legal entity** disposing of the specified Moldovan assets. Determine source, tax basis, withholding and any treaty entitlement under the cross-border method; neither route creates a universal 50% company exclusion. [Code arts. 37, 40, 71(1)(c)–(d), 91][code]; [cross-border Guide](md-cross-border.md).

### Apply the ordinary deduction procedures

Government Decision 693/2018 annex 1 supplies the operating rules below. Its latest displayed 2026 version is effective 18 June. The January/current comparison and the actual amending Decision 321/2026 show that the June changes to this business annex concern points 30 and 31; the January transport, meal and representation caps below are also retained directly. The Code prevails where a general regulatory statement is narrower or broader than the statute. [Regulation 693, annex 1][corpreg]; [January regulation][corpregjan]; [Decision 321/2026 point 2.1][corpregamend].

For an ordinary expense, record the business purpose, period, actual supplier/payee, source document, accounting treatment and any specific cap. Points 24–30 require the business connection and correct period, and permit only the business portion of mixed expenditure where business use predominates, above 50%. Recovered costs/losses/bad debts previously deducted enter gross income in the recovery year; costs never deducted use the statutory exclusion. **Do not read point 30 as overriding the specific Code art. 20(z^17) exception for provisions created in 2023–2026 when art. 87(1^1) was applied.** [Regulation points 24–30][corpreg]; [Code arts. 20(z^17), 24 and 44][code].

The membership/qualifying union alternatives in Code art. 24(15),(15^1) already applied from **1 January 2026** under Law 318/2025. The January regulation's union point 31 mentioned only 0.15% of payroll; June's regulatory update adds the alternative of up to two forecast monthly average salaries. Follow the January Code rather than incorrectly starting that statutory alternative in June, or adding both limits together. Keep the eligible organisation, actual dues/allocation and collective-agreement purpose distinct. For the two-salary alternative, the verified 17,400 forecast input gives **34,800**. [January Code art. 24(15),(15^1) and commencement annotations][jan]; [Regulation point 31][corpreg]; [Decision 321/2026 point 2.1.2][corpregamend]; [forecast input][average].

| Ordinary expense | Limit and method | Evidence and boundary |
|---|---|---|
| Organised work/dual-education transport | 75 excluding VAT per person for each actual working/transport day; reconcile monthly cost against actual transported persons and days | Internal policy/order, person's consent, route/person lists and attendance/day-worker register/dual-training contract. Third-party/public transport needs the stated service-contract/route/distance evidence. Do not apply this commute/education limit to every other business journey. [Points 34–37][corpreg] |
| Organised employee meals | 70 excluding VAT per person per actual workday. The ordinary employer's monthly average gross pay must be at least ¾ of forecast monthly average pay, **13,050 for 2026**. Compute the employer average from monthly payroll divided by average headcount, rather than treating each individual's wage as the same test | Internal policy/order and recipient list, consent, own-food cost evidence or catering contract, and attendance. The qualifying agriculture exception uses at least 70% of the stated CAEM 01.1–01.6 activities and an average-gross-pay threshold of 9,000; it took effect 1 January 2026. Points 38/40/41 also address day workers and dual/trainee categories under their own statutory routes. [Points 38–41, including 39^1][corpreg]; [January point 39^1 annotation][corpregjan] |
| Representation/delegations received | Combined deductible representation limit **0.75% of statutory gross income**. Gifts/souvenirs have their separate **2% of annual personal-exemption amount per received person/programme** sublimit; with the 2026 standard amount 29,700 this is **594** | Business-related official receptions, specified cultural events, transport, outside translators, refreshments and qualifying gifts. Keep **both** the visit order/programme with delegation composition, purpose and dates, and the documented results/expense report. This is not the employee's separate gift/voucher allowance. [Points 51–53][corpreg]; [Code art. 33(1)][code] |
| Business insurance | Classify the actual paid premium under point 55. The combined ceiling for the listed voluntary classes **55(2)(h)–(l) is 3% of gross income from all sources**, under that provision; it is not 3% separately for every policy or a cap on every insurance class | Retain policy, insured interest/property/risk, business purpose, premium and payment evidence. State-subsidised insurance deducts only the insured's required premium share. Employee voluntary medical insurance follows its separate Code cap and benefit analysis. [Point 55][corpreg]; [Code art. 24(20)][code] |

For transport/meals above the relevant cap, the regulation specifies different payroll consequences: employees have income tax, social contributions and medical premiums; day workers the stated income tax/social route; trainees/dual pupils the stated income tax/medical route. Identify the actual status and applicable base rather than applying one employee package to everybody. The taxed-payment deduction in Code art. 24(19^2)/regulation point 33^1 must be tested separately; an above-cap taxable benefit is not automatically a permanent company-tax disallowance. Use the connected payroll/social Guides for their actual rates and remaining procedures. [Regulation points 33^1, 35, 40^1][corpreg]; [Code art. 24(19^2)][code].

**Representation limits apply together.** Identify eligible costs and each gift sublimit before comparing the resulting total with the overall 0.75% ceiling. Do not add a sublimit excess twice to the same overall disallowance. Establish statutory gross income under the Code; accounting sales alone are not automatically the entire cap base. The worked source controls retain their own explicit assumptions, rather than certifying a taxpayer's delegation or income classification. [Code arts. 18, 20, 24(3), 33][code]; [Regulation points 51–53][corpreg].

Point 55 covers specified compulsory motor/carrier liability and other legally compulsory business insurance, and enumerates voluntary accident, employee life/annuity, vehicle/rail/air/ship, transit-goods, property/fire/calamity, specified liability/convention and other ordinary necessary business classes. For the property/fire categories, apply the stated ownership and covered-risk conditions; do not relabel a capped class as an uncapped catch-all. Company deductibility of an employee's insurance premium does not by itself establish the employee's tax exemption. [Regulation point 55][corpreg]; [Code arts. 19–20, 24][code].

### Employee development, recreation and required records

Business-specific professional education under point 45 must be needed for the employee's actual role/activity and incurred exclusively for business. This differs from other development/team-building under point 45^1 and Code art. 24(19^3)(b), whose **5%** base is the selected previous/current year's payroll less the specified management-group 112/121 payroll. The Code's complete base restriction controls; the regulation's general definition of payroll as salary, other work rewards and material aid does not restore excluded management amounts. Keep internal recipient/training and activity orders, contract, invoice and supporting cost records under point 46. Do not charge the same activity to both an uncapped role-required training route and the capped recreation/development route. [Regulation points 45–46][corpreg]; [Code art. 24(19),(19^3)(b)][code].

For rural-tourism reimbursement/vacation vouchers, points 44^1–44^13 require the qualifying Moldovan rural facility/authorised operator and the relevant Code cap. Accrual taxpayers need the tax invoice; cash-method taxpayers additionally need evidence of actual payment. Aggregate multiple vouchers, reimbursements and the connected sports costs within the Code's shared **50%-of-forecast-average-salary per-employee annual cap**, rather than creating separate allowances for each purchase. The current 2026 input gives **8,700**. Above-cap amounts enter the stated taxable-benefit/taxed-deduction route. [Regulation points 44^1–44^7][corpreg]; [Code art. 24(19^3)(c)][code]; [forecast input][average].

The paper voucher must show the rural facility's name/IDNO, nominal value, issue date and validity period. Employer purchase/award can cover both main and concurrent jobs under the stated rule; unused-value handling follows the operator/employer contract. A value returned by the operator after expiry enters the employer's gross income in the receipt period. The employer cannot replace a voucher returned by the employee with cash compensation. Authorisation of the actual operator/facility requires the Ministry of Culture list mentioned in point 44^7; this Guide does not certify any particular provider. [Regulation points 44^7–44^13][corpreg].

Meal vouchers are a different statutory scheme under Law 166/2017, not the organised-food 70-per-day rule or rural-vacation voucher. Points 42–44 refer to that law's actual nominal limit and the taxed-excess deduction route. The current nominal meal-voucher amount and scheme implementation remain an explicit gap; do not substitute an invented figure. [Regulation points 42–44][corpreg]; [Code art. 24(19^1),(19^2)][code].

### Donation documentation, values and losses

For an ordinary philanthropic/sponsorship deduction, verify the Code art. 36(2) eligible recipient and statutory purpose, obtain the written beneficiary request and donation/sponsorship contract, and retain the actual transfer/payment evidence. Regulation points 58–66 permit monetary and nonmonetary forms but do not remove the **5%-of-taxable-income** ceiling or recipient/purpose requirements. For cash, the contract plus payment document is required. Noncash documentation includes a contract specifying the assets/purpose, notarisation for immovable property, the relevant recipient authorisation and the prescribed tax-invoice evidence. [Code art. 36][code]; [Regulation points 58–66][corpreg].

A business gift of property has a **deemed-disposal income adjustment as well as any donation deduction**. Code art. 21(5) uses the greater of tax-undepreciated value and market value, with its explicit qualifying food-donation exception under Law 299/2022. Regulation point 64 addresses the residual-value/market comparison and nondepreciable-property book/market rule. Reconcile disposal proceeds, tax basis and the eligible donation separately; do not simply deduct the accounting expense and ignore deemed income. The food-donation exception and precise capped-base/return-line calculation need their own applicable procedure; no result for those open computations is certified here. [Code arts. 21(5), 36][code]; [Regulation points 64–66][corpreg].

Maintain loss-origin years and the version that governed each origin. Regulation points 76–78 support a tax loss based on allowed deductions exceeding gross income and require the origin-period art. 32 rules, with the legacy 2017–2022 table. Use current Code art. 32 for the applicable five-period/ordering method. The approved return and any particular historic-origin exception still require reconciliation; an old table's “unlimited” entry does not establish unlimited carryforward years. [Regulation points 76–78][corpreg]; [Code art. 32][code].

### Foreign currency and connected-party values

For ordinary income tax, Code art. 21(3) converts foreign-currency receipts/income/expenses at the official MDL rate for the transaction date. Its date rule uses the bank/payment-company statement or, in other cases, primary documents under the applicable SNC/IFRS accounting method; do not automatically use a single invoice/payment-date shortcut for every accrual. At fiscal year-end, retranslate foreign-currency debts due by/to the taxpayer at the final-day official rate, **excluding advances for assets/services**. Recognise the stipulated current/year-end exchange differences under the Code's period rules. For a currency not quoted by BNM, the provision prescribes conversion through a BNM-quoted currency using the direct relationship, then into MDL. Retain the actual rate, date, method and source evidence. [Code art. 21(3), points 1–4 including 2^1 and 3^1–3^3][code].

The SME base's specific FX/sum-difference exclusion remains separate; do not move ordinary-company exchange treatment into the 4% base. For below-market business dealings with nonbusiness individual founders/other related individuals, art. 21(6) requires its market adjustment, with the stated arm's-length/art. 19 exceptions. Ordinary currency conversion does not settle treaty residence, foreign-tax-credit timing, VAT conversion or the controlled-transaction price. [Code arts. 21(6), 54^2][code]; [cross-border](md-cross-border.md) and [transfer pricing](md-transfer-pricing.md).

### Business travel: authorise, evidence and settle each trip

Government Decision 693/2018 annex 1 point 54 directs business-travel deductions to the norms in Decision 10/2012. Use its latest displayed consolidation, effective **1 December 2024**, including the actual amending Decision 783/2024. The regulation's personnel definition includes employment/civil-contract personnel and administrators, founders and governing-body members; this is not a conclusion that every recipient has the same employee tax exemption. Domestic permanent mobile/itinerant work is excluded from its trip definition. Record the actual business mission and recipient category. [Point 54][corpreg]; [travel regulation points 1–4][travelreg]; [amendment][travelamend].

The authorised manager's order states the purpose, duration and host country. Keep the domestic order/travel authorisation, destinations, actual departure/arrival dates and supporting tickets/border evidence. A separate travel authorisation is not compulsory for a same-day return or travel between subdivisions in different localities of the same entity, but an order is still required. Reimburse actual authorised days, including departure/arrival as established by the records. [Points 6–8, 10–11][travelreg].

| Cost or decision | Ordinary method and evidence |
|---|---|
| Transport | Documented travel to/from the destination or lodging, including the specified public/economy, hired-car and taxi routes and terminal connections. The exceptional higher-class rules concern the specified category-II/official cases; they are not an ordinary private-business entitlement. Without tickets, the domestic fallback uses the competent authority's minimum regular-road/rail fare, whose actual tariff must be obtained. For a personal/hired car, retain actual route/distance, specific fuel/lubricant consumption and supporting fuel, road/parking/ferry/insurance documents; this is not a flat per-kilometre allowance. [Points 15–18][travelreg] |
| Lodging | Actual documented lodging and mandatory charges, normally subject to the destination/category ceiling per 24 hours. Invoices identify the people, period and costs. A qualifying lease can substantiate the category-A route. Varying daily room rates can be tested by the average over the whole stay. Point 19^2 separately permits the manager to approve documented lodging above the ceilings. Meals and personal services on a hotel invoice belong to the daily allowance, rather than another lodging reimbursement. [Points 19–20][travelreg] |
| Lodging without supporting documents | 50% of the applicable lodging ceiling per night, subject to point 21's exclusions where the host pays documented lodging costs in whole or part, or lodging is provided free. Use the actual applicable annex-2 ceiling in the destination table below. [Point 21][travelreg] |
| Daily allowance | Identify the mission/person category in the regulation's annex 1 and the destination/currency/rate in its separate annex 2. Private entities can choose a lower allowance, **at least 70%** of the applicable norm, under point 22^1. Departure/arrival ordinarily use the full norm; a **one-day domestic trip has no allowance**, while a one-day foreign trip uses the full norm. For foreign trips beyond **60 calendar days**, the manager can reduce the amount to **50% for each additional day**. Keep the actual applicable decision; do not multiply the 70% and 50% permissions into an invented universal floor. [Points 22–24][travelreg] |
| Transit, multiple countries and host funding | Transit exceeding 24 hours or documented forced stops uses the transit state's norm; otherwise use the destination norm. Moving between destination countries uses the arrival country's full norm for that day. Obtain the host's documented allowance/scholarship/other current-expense funding: no duplicate allowance; the regulation provides the evidenced shortfall and unmatched departure/arrival-day routes. Unjustified travel delays do not earn allowance/lodging. [Points 23, 25–26][travelreg] |
| Other costs and interruption | Retain the specified visa, banking/FX, authorised business communications, required foreign medical insurance, baggage and other qualifying documents. Point 29 has its own reimbursement rule for cancellation outside the traveller's control. Point 30 covers documented temporary incapacity for up to two months, with the hospital lodging exception; point 29(g) excludes daily allowance for hospital days. International transport crews, military/public-service and reciprocal scientific-exchange cases have separate points 28^1–36 and are not treated as ordinary office travel. [Points 29–36][travelreg] |

Keep an advance and a settlement schedule. The traveller presents the expense report and returns the unused advance within **five working days after returning to the workplace**, not five calendar days after crossing the border. Settle in the advance currency, translating other currencies from actual exchange/card evidence; without it, point 39 uses the official MDL rate on the advance date. Returning the unsupported balance uses the advance currency, or agreed MDL at the official rate on repayment. Without an advance, point 41 uses actual exchange/card evidence, falling back to the official rate on the day preceding the trip. The MDL accounting rules in points 42–43 separately use the advance-date rate, or the day-before-trip rate without an advance, and recognise the specified exchange difference. Keep these settlement/accounting rules distinct from the general Code art. 21(3) income-tax conversion rule. [Points 37–44][travelreg]; [Code art. 21(3)][code].

For **employees**, Code art. 20(d) excludes qualifying business-duty compensation within the normative limits and Government procedure, and expressly includes lodging compensation above the Government ceilings. Apply that specific lodging exception with the documented manager approval; do not automatically tax the approved excess as a daily-allowance overrun. The reimbursement entitlement, company deduction and employee PIT classification remain separate tests, including for the regulation's nonemployee personnel. Destination-rate tables and any other cap excess must be resolved before calculating an actual claim. [Code arts. 20(d), 24(3), 88][code]; [point 54][corpreg]; [points 19^2, 22–26][travelreg].

### Travel destination rates, currencies and category columns

Select the actual mission/person category under regulation annex 1 before reading annex 2: category I uses daily-allowance column I and lodging ceiling A; category II uses II and B. Category I includes the stated training, document-preparation, contract, control and other listed missions. Category II is the specifically listed officeholder/professional population, not an automatic entitlement for every company director. The actual numeric annex has separate destination, currency, I, II, A and B columns. [Regulation annex 1 category lists and ceiling mapping][travelreg]; [actual annex 2][travelrates].

| Destination in the annex | Currency | Daily I | Daily II | Lodging A | Lodging B |
|---|---|---|---|---|---|
| Republic of Moldova | MDL | 250 | 250 | 1,000 | 2,000 |
| Germany, row 75 | EUR | 75 | 85 | 210 | 230 |
| France, row 70 | EUR | 90 | 100 | 230 | 280 |
| Paris, row 71 | EUR | 90 | 100 | 250 | 280 |
| Malta, row 120 | EUR | 70 | 75 | 210 | 240 |
| Great Britain, row 121 | EUR | 80 | 90 | 250 | 270 |
| Romania, row 150 | EUR | 60 | 70 | 170 | 190 |
| United States, row 170 | USD | 110 | 120 | 300 | 350 |
| New York/Washington, row 171 | USD | 130 | 150 | 350 | 400 |

These are the published daily norms and lodging ceilings, not flat reimbursements for every trip. Apply the existing actual-cost, documentation, host-funding, one-day and authorised-reduction rules above. Use a named city's row where the annex supplies one, and use the stated currency: Great Britain's row is EUR. For other destinations, consult the linked full annex, including its specific geographic footnote; do not substitute the destination's domestic currency or a neighbouring country's rate. [Annex 2, headings, Moldova row and rows 70–71, 75, 120–121, 150, 170–171][travelrates].

For an assumed category-I Germany mission with three eligible allowance days and two nights supported by invoices of EUR 195 each, the norm allowance is `3 × 75 = EUR 225`; lodging is `2 × 195 = EUR 390`, below `2 × 210 = EUR 420`. These two components total EUR 615 before transport and currency conversion. If the private entity instead validly chooses 70% of the norm, the allowance is EUR 157.50 and these components total EUR 547.50. In a separate qualifying case without lodging documents and without the point-21 host-funding exclusions, `2 × 50% × 210 = EUR 210` is the lodging amount, not EUR 390. A one-day domestic trip still has no daily allowance despite the annex's MDL 250 norm. These are assumed reimbursement working papers, not a conclusion on every recipient's employee exemption. [Points 19–24 and annex 1][travelreg]; [annex 2 row 75 and Moldova row][travelrates].

### Asset life, depreciation, repairs and disposals

Use Government Decision 704/2019, latest displayed version effective **1 January 2025**, with the current Code art. 26^1. Maintain each asset separately; the approved register is annex 1, and the rented-asset repair calculation is annex 2. Their actual column mapping is set out below from the downloaded annexes. Keep acquisition cost and directly attributable commissioning costs, business use, ownership/lease status, commissioning/disposal dates, chosen lawful life, capitalised subsequent costs and accumulated **tax** depreciation separately from book values. Capital contributions can be depreciable qualifying assets; land, construction in progress and the listed nondepreciable property are excluded. Seasonal use, repair, modernisation or conservation does not stop depreciation if the asset remains in service. [Code art. 26^1][code]; [asset regulation points 2–11][assetreg].

The current life-selection rules are in Decision 941/2020, **2022 consolidation**, rather than the older repealed catalogue. For a business, use the financial-accounting useful life, subject to the annex's minimum rather than its maximum. Follow the specific manufacturer's technical-documentation life where point 13 applies. Used assets have a tax life of at least **50% of the annex minimum**. For an unlisted/self-created asset or component, the internal commission, independent expert or manufacturer/supplier/distributor recommendation establishes the life with subsequent management approval. Identify the actual asset/category/code and supporting documents; selected numerical rows from the actual annex are set out below. [Catalogue points 9–15, 17–19][assetcatalogue].

Ordinary straight-line depreciation starts in the **month after commissioning**, and capitalised subsequent costs start in the month after capitalisation. The final depreciation month includes expiry, withdrawal from service or disposal. Compute `depreciable value × (1 / useful life in years) × eligible months / 12`; equivalently use a life in months consistently. Reconcile the last-period total with the available basis. The regulation also prorates months when a business first becomes entitled to deductions on moving from a special regime; it has particular adjusted-basis rules for that change and withdrawal of IT-park residence. Finance/operating leases and IFRS right-of-use assets follow their distinct statutory owner/deduction rules. [Code art. 26^1(4)–(7)][code]; [regulation points 2, 10–19][assetreg].

For a business outside CAEM section K financial/insurance/reinsurance activities, accelerated depreciation is an option: up to **50% of entry cost in the first year of use**, then the undepreciated value divided by remaining useful life. That first year is **12 consecutive months of useful life**, not automatically the calendar year of purchase. Record the election, actual qualifying months, tax depreciation already taken and remaining life; do not take a full first-year amount twice across two calendar returns. [Code art. 26^1(6^1)][code]; [regulation point 16^4, amendment effective 1 January 2025][assetreg].

Separate servicing/maintenance from repair and capital improvement. SNC/IFRS current expenses follow Code art. 24(1); capitalised improvements increase entry cost and depreciation uses the adjusted undepreciated basis over the remaining life from the next month. Life extensions/reductions follow catalogue points 10–11, including the minimum-life safeguard. For qualifying rented/leased/concession assets whose repairs are borne by the user, the Code normally caps current deduction at **15% of accrued annual rent/operating-lease/concession charges**; the specified international-aircraft route uses 100% of operating-lease charges, and own taxi-vehicle repairs have their separate 100% rule. Regulation point 28 permits full current deduction of the specified leased/rented/other-use-contract repairs where the contract lasts **up to 12 months inclusive**. Do not apply a universal 15% cap to owned-asset maintenance. [Code arts. 24(1), 26^1(3), (11)–(11^1)][code]; [regulation points 20–28][assetreg]; [catalogue points 10–11][assetcatalogue].

An applicable repair excess becomes a separately registered tax asset when the work is complete. Its starting life is the shorter of remaining contract term and the underlying asset's useful life; the entity can elect a longer life. Multiple repairs can be one investment asset or separate ones under point 29. If the contract is terminated, point 30 retains the investment in the register and continues depreciation over its originally fixed duration. Obtain the actual contract, repair allocation and completion records before deciding the route. [Points 24–30][assetreg].

On disposal, determine tax undepreciated value from entry/capitalised cost less tax depreciation **through the disposal month**. A sale's tax result is proceeds less that value. A donation produces the positive excess of market value over tax undepreciated value, or zero where the latter is higher, subject to the Code's specific controlling exceptions. An exchange uses the received asset's contractual value adjusted for extra cash receivable/payable, less the transferred asset's tax undepreciated value. A capital contribution uses the participation interest's value less the transferred asset's tax undepreciated value. **Forced loss or early scrapping does not automatically deduct the remaining tax value**: where qualifying insurance/co-insurance compensation is taxable under Code art. 18(i), point 36 permits deduction only up to that taxable income. Historical capped-car and transition assets have separate points 33^1, 35^1 and 38–45; keep their original-period schedules instead of resetting their tax basis to book value. [Code arts. 18(i), 21(5), 26^1(17)][code]; [regulation points 31–45][assetreg].

### Actual asset classes and approved tax-register fields

Identify the category, tariff code and complete description together. The following are selected rows of the actual catalogue annex; the published upper number is not a business taxpayer's mandatory maximum because current point 9 uses the financial-accounting life subject to the minimum, with point 13's manufacturer-documentation exception. Apply the separately stated used-asset/unlisted-asset rules where relevant. [Catalogue points 9, 12–15][assetcatalogue]; [actual numeric annex][assetlifetable].

| Category and code | Actual class | Published life interval, years |
|---|---|---|
| 14 / 8471 | Listed automatic data-processing machines and units, excluding the following specific POS row | 3–5 |
| 14 / 8471 90 000 | POS terminal | 5–7 |
| 15 / 8703 | Listed passenger cars and other mainly passenger vehicles, excluding heading 8702 | 5–7 |
| 16 / 9403 10 | Metal office furniture | 9–10 |
| 16 / 9403 30 | Wooden office furniture | 4–6 |

For example, an otherwise ordinary new 8471 asset with a documented four-year financial life clears the three-year minimum; the specific POS row has a five-year minimum. A new metal office-furniture asset with an eight-year financial life requires a nine-year tax life unless the manufacturer-documentation exception applies. The catalogue minimum does not settle the passenger-car cost cap, business use, ownership or depreciation election. Other asset classes must be matched to their own full description and any parent/exception rows in the official annex; only the five rows above are applied here. [Catalogue points 9–15][assetcatalogue]; [selected annex rows][assetlifetable].

The actual HG704 annex-1 register has 29 columns and accompanying instructions. Maintain the inventory number/name in columns 1–2, and distinguish its depreciable basis from gross entry/capitalised cost. [Annex 1 form and instructions 1–29][assetregister].

| Register area | Field method |
|---|---|
| Before repair, columns 3–12 | Column 3 is depreciable value; 4 is entry/capitalised cost; 5 is the established useful life; 6 is life used for depreciation; 7–8 are accumulated tax depreciation and consumed months brought forward. Columns 9–12 record rate, start month, eligible current months and current depreciation. For an existing asset, prior-period columns 24–29 feed current columns 3–8 respectively. Historical-transition assets follow the specifically stated chapter-IX inputs instead. |
| Capitalisation and adjusted basis, 13–18 | Column 13 is capitalised repair/development cost; 14 is the post-capitalisation depreciation start month; 15 is the established life after the change. Column 16 = 7 + 12; 17 = 8 + 11; adjusted depreciable value 18 = 4 − 16 + 13. |
| Remaining life and annual depreciation, 19–23 | Remaining life 19 = established life 15 − consumed life 17, after expressing both in the same unit. Rate 20 is 100% divided by remaining life; 21 is the post-repair eligible month count; 22 is the corresponding depreciation. Annual depreciation 23 = 12 + 22. Use an annual rate as a fraction when multiplying basis and months/12, or calculate directly as basis/life-in-months × eligible months. Do not subtract months from years or use numeric 20 where 20% = 0.20 is intended. |
| Next-period basis and life, 24–27 | Column 24 takes 3 without repair or 18 after repair; 25 takes 4 or 4 + 13; 26 takes 5 or 15; 27 takes 6 or 19. Column 25 retains capitalised cost, rather than being the same as the depreciable basis in 24. |
| Next-period accumulated amounts, 28–29 | Column 28 = 7 + 23. Column 29 is 8 + 11 without repair or 17 + 21 after repair. Do not complete this next-period section for assets withdrawn from service or disposed of during the period. |

The register expressly permits lives in months. Reconcile those units with the main regulation's annual-rate/month-count formula, and preserve the actual percentage convention in the working paper. The older register layout alone does not verify how a filing system implements the accelerated method introduced later. [Annex 1 instructions 9, 12, 19–29 and final note][assetregister]; [main regulation points 13–16^4][assetreg].

For qualifying rented-asset repairs, actual annex 2 has seven columns: serial number and asset in 1–2; period rental expense **excluding VAT** in 3; the applicable Code art. 26^1(11) percentage times column 3 in 4; actual repair costs in 5; current deduction `min(5, 4)` in 6; and the separately recognised tax asset `5 − 6` in 7. First test the contract-duration and special statutory routes above. In an assumed ordinary contract longer than 12 months with MDL 100,000 qualifying rent excluding VAT and MDL 22,000 repairs, the 15% route gives column 4 of MDL 15,000, current deduction MDL 15,000 and a separately depreciable repair asset of MDL 7,000. This is not a 15% deduction of the repair invoice or permission to depreciate the landlord's entire asset. [Code art. 26^1(3), (11)][code]; [HG704 points 24–30][assetreg]; [actual annex 2 columns 1–7][assetrepair].

## Deadlines and filing

| Obligation | Statutory method | Source |
|---|---|---|
| Ordinary company/PE return | By the 25th of the third month after the tax period ends; obligation exists even with no tax payable, subject to the stated statutory exceptions | [Art. 83(2), (4)][code] |
| Ordinary final payment | By the return's statutory due date, without treating a filing extension as a payment extension | [Art. 87(1)][code] |
| Ordinary instalments | 25 March, 25 June, 25 September, 25 December: each one quarter of current estimated tax or preceding-year tax; approved non-calendar periods use the statutory three-month schedule | [Art. 84(1), (5)][code] |
| Agricultural instalment alternative | One quarter by 25 September and three quarters by 25 December | [Art. 84(2)][code] |
| SME regime | Pay quarterly by the 25th of the following month; annual return by 25 March of the following year | [Art. 54^4(2)–(3)][code] |
| Current-profit dividend advance | Company pays 12% of the current-period profit from which dividends are paid, by the 25th of the following month; credit against its own annual tax; stated SME/IT-park exceptions apply | [Art. 80^1][code] |
| Withholding remittance/monthly report | By the 25th of the month after the payment; distinguish the annual information return and recipient-information duties | [Art. 92][code] |

### Select the return for the regime and reporting year

| Established taxpayer/regime | Approved return and period rule | Primary source |
|---|---|---|
| Ordinary business-income taxation within VEN12’s population | **VEN12**, approved by MF Order 153/2017 and amended by Order 145/2024; use the actual reporting-period rules and the verified row changes below | [MF Order 153/2017][ven12order]; [Order 145/2024][ven12amend] |
| Eligible chapter-7^1 SME income regime | **SIMM24** under MF Order 143 of **27 November 2024**, published/effective **30 November 2024**, for reporting periods **from 2024**. **2023** is the final SIMM20 reporting period | [MF Order 143/2024, points 1–3][simm24order]; [Code arts. 54^1–54^4][code] |

Order 143 point 4 preserves the form in force on actual submission where the reporting obligation arose before the new order was approved/published. Keep that narrow transition separate from the normal 2026 SME route; do not select SIMM20 because an old catalogue entry or spreadsheet remains available. The SME label also does not establish eligibility: apply the VAT, activity, ownership, election and period rules above before selecting SIMM24. The annual return and quarterly payments remain distinct duties. [MF Order 143 points 2–4][simm24order]; [Code arts. 54^1–54^4][code].

The enacted order approves the form and completion instructions as annexes 1–2. Both linked Word files were downloaded, retained unchanged, rendered and read. The actual form says **SIMM24M** and still prints category **B** for chapter **7^3** metal trading, although the enacting order names SIMM24 and the current Code marks chapter 7^3 repealed. Do not infer a current metal-trading regime from that old printed category. The method below is for currently eligible chapter-7^1 taxpayers, **category A**; the exact live portal name/version and obsolete-category handling remain untested. [MF Order 143 point 1][simm24order]; [actual linked form][simm24form]; [completion instructions 1–21][simm24instructions]; [current Code chapters 7^1, 7^3][code].

### SME worksheet from the actual annex

Use registered taxpayer identity, the territorial SFS unit, **A/year** reporting-period code, four-digit CUATM and four-digit CAEM activity code. Establish category-A eligibility under the current Code before using the printed category. [SIMM instructions 1–9][simm24instructions]; [Code art. 54^1][code].

| Actual form row | Category-A working-paper method | Source |
|---|---|---|
| 1 | Total recognised financial-accounting income | Instruction 10 |
| 2 | Article-20 income excluded by Code art. 54^2(3) | Instruction 11 |
| 3–4 | Qualifying returns and discounts that reduce this period's base. The instructions use these separate rows where sale and return/discount occur in different reporting periods; do not deduct same-period items again when already reflected in recognised income | Instructions 12–13 |
| 5 | Excluded exchange-rate income; keep it distinct from other exclusions and verify any current statutory sum-difference income's actual field treatment | Instruction 14; Code art. 54^2(3) |
| 6 | **max(row 1 − row 2 − row 3 − row 4 − row 5, 0)**. A negative result is reported as zero | Instruction 15 |
| 7–8 | Current category-A **4%** rate; row 8 is row 6 × row 7 | Instructions 16–17; Code art. 54^3 |
| 9–10 | Eligible article-82 foreign income-tax credit in row 9, subject to its proof and cap; **row 10 = row 8 − row 9** | Instructions 18–19; Code art. 82 |

Sources for the table: [actual one-page form][simm24form], [completion instructions 10–19][simm24instructions] and the cited [current Code][code]. Keep exclusions disjoint: do not remove the same income or return twice. Row 10 is the calculated annual tax after the eligible foreign credit; the form has no separate quarterly-instalment deduction row. Reconcile actual quarterly payments separately to the taxpayer account and payment balance. The existing SME example's annual tax and remaining cash balance are different amounts, not two competing row-10 figures. Subdivision taxpayers transfer the tax to the main legal-address budget under instruction 20 and Code art. 54^4(5). Instruction 21 permits the head's signature alone or the stated authorised two-signature route. Current sum-difference routing, rounding and portal validation remain specific implementation checks. [Instructions 18–21][simm24instructions]; [Code arts. 54^2–54^4, 82][code].

**Dividend-linked company-tax deferral for 2023–2026 profit.** Test at the period's final day: at most 249 employees and turnover up to 100 million, or at most 249 employees and assets up to 100 million. The rule excludes the listed individual/farm, free-zone/free-port/free-airport, IT-park, SME-regime and financial/insurance taxpayers. It also excludes the stated section-G businesses above 49 employees and the applicable 50-million turnover/assets test. Exercise the option through the art. 83 return. Tax becomes payable by the 25th after the month dividends are paid, including share distributions. For profit originating in the 2026 tax period, apply the current statute's prorata of gross dividend paid to total pre-tax financial-statement profit for that origin period, rounded as the statute requires, to that period's calculated company tax. Preserve the origin-year profit/tax and all prior distributions. For distributions from earlier origin years, establish the version governing that year's election and calculation before selecting the denominator; this draft does not certify that the current pre-tax denominator applies retrospectively to every earlier year. Article 84(6) excludes this class from ordinary instalments for 2023–2026. Law 41 removed the old blanket sentence rejecting corrected returns aimed at changing the option, and its art. X(2) specifies retrospective-period application. Exact return-line prorata/rounding and corrected-election implementation remain an explicit draft gap; do not invent a calculation or ignore the option. [Arts. 84(6), 87(1^1)][code]; [Law 41 arts. I(2)–(3), X(2)][amend].

**Approved ordinary business return.** MF Order 153/2017 approves VEN12 and its completion instructions as annexes 1–2. The latest consolidation displayed in the official register is amended by Order 145 of 29 November 2024, effective 5 December 2024. The original linked form (DOC) and instructions (DOCX) have now been retained unchanged and fully text-read, rendered and visually checked: seven form pages and twelve instruction pages. Main-return and annex methods are supplied below. Their S-election paragraph still names 2023–2025 and does not override the current Code's 2026 population or years. The printed **360,000** personal-exemption threshold agrees with current Code article 33; it is not an obsolete amount. Apply the full current annual-income test, including article 33(1^1), instead of treating an unchanged number as proof that every eligibility condition was checked. [MF Order 153/2017][ven12order]; [Orders 145/2024][ven12amend] and [10/2024][ven12assetamend]; [selected VEN12 instructions][ven12instructions]; [Code arts. 33, 87][code].

### Ordinary VEN12 reconciliation

For an ordinary resident legal person, retain a row-by-row working paper. Use the applicable **A/year** calendar-period code, **PT/year** transition-period code or **PM/year** modified-period code from instruction 1, after establishing the lawful reporting period. Instructions 2–6 require the registered taxpayer identity and four-digit CAEM activity code; the return can be signed by the head alone, or by the stated authorised first/second signatories. A valid period/signature does not establish tax-regime eligibility. [VEN12 instructions 1–6][ven12instructions]; [Code arts. 12^1, 54^6, 83][code].

| Return row | Reconciliation for the established ordinary legal-person route | Completion instruction |
|---|---|---|
| 010; 0101; 0102 | Start with **pre-tax accounting profit or loss** in 010; preserve a loss's negative sign. 0101 and 0102 contain recognised accounting income and expenses | 7–9 |
| 020; 030; 040 | Transfer the respective annex 1D income and annex 2D expense adjustments. **040 = 010 + 020 − 030**. Preserve signed adjustments: an accounting expense disallowed for tax can make the expense adjustment negative | 10–12; annexes 1D/2D |
| 050; 060 | Record the **allowed**, separately determined philanthropic/sponsorship deduction and ordinary undocumented-expense deduction. The approved form specifies ceilings of **040 × 5%** and **040 × 0.2%**, respectively. Apply the actual qualifying amounts and current Code conditions | 13–14; approved form rows 050–060 |
| 070; 100 | For a legal person, 070 is **max(040 − 050 − 060, 0)**. Record a negative result's magnitude, without a minus sign, in loss row 100. Personal-relief row **0701 belongs to natural-person taxpayers**, not an ordinary SRL | 15–16, 20 |
| 080; 0901 | Deduct only the qualifying carried-forward loss, in statutory order, **not exceeding 070**; **0901 = 070 − 080**. An expired or unsupported prior loss does not qualify because the return has a loss row | 17–18; Code art. 32 |
| 0902; 090 | Record only applicable exempt income, **not exceeding 0901**; **090 = 0901 − 0902**. Keep the specific relief authority and annex 4D | 19–20 |
| 110; 120; 130; 150 | Use the applicable rate in 110, **120 = 090 × 110**, and authorised tax relief from annex 6D in 130; **150 = 120 − 130**. For the ordinary SRL route the current Code rate is **12%** | 21–25; Code art. 15(b) |
| 140 | The tax associated with exempt income is **informational**. Do not subtract 140 again when calculating rows 150–200 | 24 |
| 160; 1601; 170 | Instruction 26 makes 160 the article-82 foreign-tax credit in 1601. Keep its foreign-income/tax evidence and cap; **170 = 150 − 160** for a positive result. A negative result follows the stated row-200 route and does not populate annex 10D | 26–27; Code art. 82 |
| 1801; 1802; 180; 190; 200 | Separate ordinary instalments and qualifying current-profit dividend advances; **180 = 1801 + 1802**. A payable balance uses **190 = 150 − 160 − 180**; an excess payment uses the reverse difference in **200**. Keep payment records and prior-credit allocation | 28–31; Code arts. 80^1, 81, 84 |

Sources for the table: [VEN12 instructions 7–31][ven12instructions], [approved form, selected actual text][ven12form] and the cited [current Code articles][code]. This ordinary route does not certify the old instruction's S-election treatment for 2026, all withholding-credit categories, refund approval or electronic field validation. Annex 10D allocation is supplied below. Current law and the actual taxpayer's relief/credit restrictions control; no software or filing acceptance is inferred from the arithmetic.

**Ordinary cash-donation and undocumented-expense cap working paper.** Where accounting profit already includes the cash philanthropic/sponsorship cost and ordinary article-24(10) undocumented expense, annex 2D **03025** and **03026** put those book amounts in column 2 and zero in column 3. The annex's adjustment is **column 3 minus column 2**; subtracting that negative adjustment when calculating 040 adds the costs back once. The approved form then uses **040**, before rows 050–060 and loss relief, as both percentage-cap bases. Deduct in 050 the lesser of the actual qualifying cash donation and **5% of positive 040**; deduct in 060 the lesser of the actual qualifying ordinary undocumented expense and **0.2% of positive 040**. If 040 is not positive, these capped deductions are zero. Do not add the costs back twice, apply the percentages to post-deduction 070/090, or solve an invented simultaneous circular formula. Establish eligible recipients, purpose, proof and ordinary necessary business use first. Article **24(10^1)** business-card purchases have a separate statutory route; do not automatically place them under this capped ordinary article-24(10) route. Noncash/food donations and other special adjustments require their own classification and remain outside this cash-only illustration. [Approved VEN12 form, main rows 040–060 and annex 2D columns/03025–03026][ven12form]; [instructions 12–14, 79–80][ven12instructions]; [Code arts. 24(1), (10), (10^1), 36][code].

**Representation expenses: use the current instruction rather than obsolete printed rows.** Annex 2.1D instructions 102–102^3 direct the Government point-53 coefficient to **row 03043 column 3**, with the corresponding cap in column 4. The current Government rule is **0.75% of statutory gross income**. Old rows **030431, 030432 and 03044 are not completed**. For the ordinary case where all recorded costs meet the purpose, evidence and gift-sublimit conditions, record the **actual accounting costs** in **03045 column 4**, then the lesser of those costs and the cap in **03046 column 4**. Transfer 03045 to **annex 2D row 0304 column 2**, and 03046 to **row 0304 column 3**. Keep the accounting amount distinct from any eligibility disallowance: do not replace actual book costs with a pre-screened subtotal or count a gift-sublimit excess twice. The simple field calculation above assumes all recorded costs qualify; additional eligibility adjustments need their own reconciliation. Old goods/services percentage rows are not additional deductions. [VEN12 instructions 58, 102–102^3][ven12instructions]; [Government regulation points 51–53][corpreg].

**Do not reactivate the old capital-gain annex.** Instruction **53^1** says VEN12 **annex 1.2D is not completed from reporting year 2020**. A legacy printed percentage in that annex is not a current SRL inclusion rule. Apply the current business-income and fixed-asset disposal rules, while the individual-only chapter-5 rule remains in the individual Guide. [VEN12 instruction 53^1][ven12instructions]; [Code arts. 14, 18, 24, 37, 40][code].

**Verified transfer-pricing return rows.** Order 145/2024 adds VEN12 **annex 1D row 02020** for income adjusted under Code art. 226^23(1), and **annex 2D row 03047** for the corresponding expense adjustment. The enacted amendment identifies completion-instruction points **51^1** and **100^1**; the actual consolidated instruction attachment prints the expense addition as **101^1**. Both identify the same **03047** expense row. Its row identity, rather than the inconsistent paragraph label, governs the reconciliation; points 52 and 101 extend their respective aggregation ranges to 02020 and 03047. The order entered into force on publication, **5 December 2024**, and applies from the **2024 reporting period**; its point 3 preserves the then-effective form for an obligation arising before approval/publication. Under Code art. 226^23(2), voluntary adjustments for prior periods also require corrected TP information/file and corrected tax returns under art. 188. Retain the adjustment calculation and year/form version; the actual annex columns and full instructions are now retained and mapped below, while portal acceptance remains untested. [Order 145/2024 points 1–3][ven12amend]; [Code art. 226^23][code].

**Verified fixed-asset loss rows.** Actual MF Order 10/2024 replaces completion-instruction point 74: VEN12 **row 03020, column 2** records the fixed-asset disposal loss recognised in financial accounting; **column 3** records the loss recognised for tax. It includes donation losses **except** philanthropic/sponsorship donations, which belong in **row 03037**. Keep those two loss measures and the charitable-donation classification distinct; row placement does not itself allow a tax loss or settle the donation cap. The order entered into force on **1 February 2024** and applies from reporting period **2023**. The subsequent Order 145/2024 adds the TP rows above and does not replace this point 74. The complete form and instructions now corroborate point 74 and the separate 03037 route; specialist entitlement and portal implementation still require their own evidence. [Order 10/2024 points 1(1)(b)–(c), 1(2)(b), 2][ven12assetamend]; [Order 145/2024][ven12amend]; [Code arts. 21, 24, 26^1, 36][code].

### Complete the actual VEN12 annexes

Keep an adjustment schedule with the **accounting amount in column 2**, the **tax amount in column 3** and the **signed difference, 3 − 2, in column 4**. Annex 1D totals income rows into main **020**; annex 2D totals expense rows into main **030**. Because main **040 subtracts 030**, a negative expense adjustment increases taxable profit. Classify the transaction and establish current legal eligibility before choosing the row: a printed tax column does not itself authorise a deduction or exemption. [Actual annexes 1D/2D][ven12fullform]; [instructions 32–101, including 51^1/101^1][ven12fullinstructions]; [Code arts. 20–25, 31, 44][code].

| Annex 1D row | Source field route and current-law boundary |
|---|---|
| 0201; 0202; 0203 | Promotional winnings are entered in accounting column 2 with the printed tax zero. Instructions expressly disable 0202 from 2017 and leave 0203 unused. The old interest labels are not current exemption claims. |
| 02041; 02042 | For qualifying forced-loss replacement, compensation recognised in accounting goes in 02041 column 2, tax zero. Unreinvested or partly unreinvested compensation follows 02042 tax column 3 after the permitted replacement period. Current article 22 requires a forced loss and replacement of the same nature; the period expires in the following fiscal period. Replacement basis is the old basis plus qualifying acquisition expenditure not covered by the forced-loss proceeds. Record the loss, compensation, reinvestment and dates separately. |
| 0205 | Cash-to-accrual changeover: accounting column 2 records the changeover surplus in the first period; tax column 3 records one third in that period and each of the following two periods. Apply only to the surplus caused exclusively by the change; article 44(8) prevents omission or duplication. |
| 0206 | Positive fixed-asset disposal result: accounting gain in 2 and the independently calculated tax gain in 3. A loss follows the separate 03020 route; do not net unrelated asset results without the supporting schedule. |
| 0207 | Donation deemed-sale income from annex 1.1D enters tax column 3; accounting column 2 is unused. Apply the noncash method below and the current food-donation exception. |
| 0208; annex 1.2D | Unused from reporting 2020. The actual form still prints a historical **20%** multiplication; neither that percentage nor any other legacy percentage is a current company inclusion rule. |
| 0209 | Recovery of a debt whose earlier write-off was disallowed: accounting amount in 2, tax zero. Keep the earlier disallowance to prevent taxing the recovery twice. |
| 02010 | Nonmonetary income: accounting value in 2 and the article-21(1) tax valuation in 3. Use the preceding month's average comparable selling/service price; when no such previous-month supplies exist, current statutory cost is the floor. |
| 02011–02018 | Separate capital-contribution exchange, qualifying special-fund/grant receipts, legally exempt cancelled sanctions, incentive income, insolvency debt cancellation, revaluation, SNC-to-IFRS transition and resident-to-resident dividends. The form supplies separate rows; apply the current article-20/44/55 conditions before removing book income. A grant label, debt cancellation or dividend label alone does not establish exemption. |
| 02019; 02020 | Other income adjustments use 02019. Its old broad related-party wording is restricted by current article 21(6): the specified nonbusiness individual founder/related-person transactions, with arm's-length and article-19 exceptions. Article-226^23 voluntary TP income adjustments use 02020. |

Sources for the income table: [actual annex 1D][ven12fullform]; [instructions 32–53^1][ven12fullinstructions]; [current Code arts. 20–22, 44, 55, 226^23][code]. Retain the current legal conditions alongside each field; specialist incentive and contribution transactions need their own operative-law working paper.

| Annex 2D rows | Accounting-to-tax routing |
|---|---|
| 0301; 0306; 0309; 03019 | Separate private/family expense, unjustified related-person payments, exempt-income expense and statutory fines. Record the accounting amount in 2 and the applicable tax zero. |
| 0302–0304; 03010; 03012–03013 | Travel, insurance, representation, interest, depreciation and research use book amount in 2 and the independently allowed tax amount in 3. Apply the sourced limits, asset method and research exclusions above. |
| 0305 | Related-party loss row: current article 24(8) and the Government regulation contain arm's-length and cooperative/producer-group exceptions. The printed zero does not cancel those current exceptions; retain the actual annual related-party loss computation and legal classification. |
| 0307; 0308 | Unpaid expense owed to a cash-accounting related person is disallowed in 0307. When an earlier disallowed amount is paid, its allowed tax deduction enters 0308 column 3, with accounting zero. Link the original and payment-year schedules; do not deduct it twice. |
| 03014–03016 | Ordinary provisions: book provision in 03014 column 2, tax zero. Qualifying bad-debt write-offs use 03015 book/tax amounts. Eligible current business expenditure applied against a previously disallowed provision enters 03016 tax column 3, with accounting zero. Financial-institution/insurer/nonbank allowances in 03017/03018/03042 are distinct specialist populations. |
| 03020–03023 | Fixed-asset disposal loss uses separate book/tax amounts in 03020, with philanthropic donations routed to 03037. Other fixed-asset exits, including forced loss, use 03021 accounting amount. Intangible depreciation and natural-resource deductions use separate book/tax amounts in 03022/03023. The field does not determine the statutory loss, basis or allowance. |
| 03025; 03026; 03037; 03038 | Cash philanthropy and ordinary undocumented expense are added back through 03025/03026 before the main-return capped deductions. Noncash philanthropy uses the separate book/tax reconciliation in 03037 and donation-income 0207. Other cash donations use 03038; a donation outside article 36 is not entitled to row-050 relief. |
| 03027–03031 | Separate statutory land-recultivation/agricultural-loss provisions, disallowed employee payments, patent/independent-retail payments and waste/shrinkage. For 03030 apply current article 24(11)'s actual exceptions rather than a blanket prohibition. For 03031 tax column 3 follows the annually approved management norms under article 24(13). For tobacco headings 240210000, 240220, 240290000, 2403 and 2404, ethyl alcohol headings 2207 and 2208, and petroleum products, those norms cannot exceed the limits set by the Ministry of Health, Ministry of Agriculture and Food Industry, and Ministry of Infrastructure and Regional Development, respectively. The actual sector limits remain unconfirmed here; do not calculate a sector deduction from the management norm alone. |
| 03032–03036 | Inventory net-realizable-value and short-term investment write-downs have tax zero in 03032/03033. Rented-asset repairs use 03034 and the applicable statutory cap. Capital acquisition expenditure goes to 03035 only if it has already affected accounting profit. Audit-risk provisions/professional-liability insurance in 03036 are the specified audit population, not a general-company allowance. |
| 03039–03041; 03044; 03046; 03047 | Separate excess pollution/resource charges, qualifying membership costs, revaluation/impairment, nonrecognised SNC-to-IFRS expense and remaining disallowed expense. Membership 03040 has independently established book/tax amounts; revaluation/IFRS tax zero is not a cash-payment test. Voluntary TP expense adjustments use 03047. |
| 03011; 03024; 03043; 03045 | The completion instructions leave these legacy rows unused. Do not populate them merely because the old labels remain printed. |

Sources for the expense table: [actual annex 2D][ven12fullform]; [instructions 55–101^1][ven12fullinstructions]; [Code arts. 23–31, 36, 44, 226^23][code]; [Government regulation, including points 64–65, 74–75][corpreg]. Preserve the earlier deduction/evidence sections: this table locates the established adjustment, rather than granting every listed special deduction.

**Noncash donations require both sides of the reconciliation.** For an ordinary donated business fixed asset, annex **1.1D column 2** is its undepreciated tax value; for other current assets it is book value. Column **3** is market value at donation; column **4** is the larger amount, transferred to **1D 0207 column 3**. Separately, philanthropic/sponsorship **2D 03037 column 2** records the book value disposed of, while **column 3** records the undepreciated tax value for the used fixed asset, or book value for other current assets. Do not confuse the deemed-sale price, deductible asset cost and capped philanthropic deduction. Confirm article-36 recipient/purpose, the written recipient request and donation agreement; real-estate agreements require notarisation, and the Government rule specifies the supporting authority/invoice evidence. The instructions also direct the qualifying philanthropic amount to **main 050**, under the same **5% of positive 040** cap. The exact current deductible-value reconciliation and VAT treatment for each asset/recipient remain a specific working-paper check; simply carrying the maximum deemed-sale price into 050 is not established by these form fields. Qualifying food donations under Law 299/2022 are expressly excepted from both Code 21(5)'s ordinary deemed-sale rule and Code 36(1)'s ordinary philanthropic cap route, so keep that special regime separate. [Instructions 13, 39, 53, 91][ven12fullinstructions]; [actual annexes 1.1D/2D][ven12fullform]; [Code arts. 21(5), 36][code]; [HG693 points 58–65][corpreg].

For example, assume a qualifying non-food fixed-asset donation has book value **30,000**, tax undepreciated value **20,000**, market value **25,000**, and accounting profit **170,000** after its book disposal. Annex 1.1D/0207 gives **25,000** tax income; 03037 gives an expense adjustment of **20,000 − 30,000 = −10,000**. With no other adjustments, **040 = 170,000 + 25,000 − (−10,000) = 205,000**, and its main-050 percentage ceiling is **10,250**. Those are field controls, not a conclusion that every MDL 10,250 is deductible: establish the qualifying donation-value/evidence/VAT reconciliation before completing 050. [Instructions 12–13, 39, 53, 91][ven12fullinstructions]; [actual form][ven12fullform]; [Code arts. 21, 36][code].

**Separate relief against income from relief against tax.** Annex **4D** records the official facilitation code, supporting law number/date and qualifying exempt income, capped at main **0901**; column **3** totals to **0902**. Column **4**, calculated at the applicable ordinary rate, totals to informational **140**. Annex **6D** records its separate code/law, relevant calculated tax in column **3**, **the percentage not payable** in **4**, and their product in **5**, totalling to **130**. If an independently established entitlement requires payment of 75% of ordinary tax, the relief percentage is **25%**, not 75%. As an assumed arithmetic check, 60,000 income before relief, 10,000 genuinely exempt income and ordinary 12% tax give 090 of **50,000**, 120 of **6,000** and informational 140 of **1,200**. If separate lawful relief applies to 2,400 of that calculated tax at 25%, 130 is **600** and 150 is **5,400**; do not subtract 140 again. The printed education/free-zone examples do not prove current eligibility or the current classifier code for a real claimant; those require the operative incentive law and classifier. Annex **5D is unused**. [Instructions 19, 23–25, 116–118^5][ven12fullinstructions]; [actual annexes 4D–6D][ven12fullform]; [Code art. 15][code].

**Foreign credit: complete each country calculation before the main transfer.** In annex **7D**, record country code **16011**, foreign income **16012**, related expense **16013**, net foreign taxable income **16014 = 16012 − 16013**, total taxable income **16015 = main 090**, income percentage **16016 = 16014 ÷ 16015 × 100**, and tax after relief **16017 = main 150**. Eligible foreign tax actually paid is **16018**; allocated Moldova ceiling **16019 = 16016 × 16017 ÷ 100**; allowed **16020 = min(16018, 16019)** transfers through main **1601** to **160**. Apply Code 82's same-income, official-payment-proof, period and maximum-Moldova-tax restrictions. With positive total taxable income 200,000, foreign net income 50,000, main-150 tax 18,000 and qualifying foreign tax 6,000, the share is **25%**, ceiling **4,500** and allowed credit **4,500**, not 6,000. A zero/loss denominator or overlapping relief needs its own statutory allocation; do not divide by zero or use a negative percentage as an automatic refund. The actual form's grey historical **1602** withholding row is not included in the current main-160 formula, which names 1601 only. [Instructions 26, 119–128][ven12fullinstructions]; [actual main form/annex 7D][ven12fullform]; [Code art. 82][code].

**Founders are a separate taxpayer route.** Annex **3D** belongs to business taxpayers with natural-person status, not an SRL. Columns **2–5** identify the founder, dependants and spouse; **6/7**, **9**, **10/11** record the applicable personal/increased, spouse and dependant reliefs. Column **8 is unused from 2021**. Apply the current Code 33–35 conditions and the ordinary personal exemption's strictly-below-360,000 annual-income gate, including article 33(1^1); do not reuse the same relief elsewhere. Column **12** and main **0701** cannot exceed positive **040 − 050 − 060**; any unused founder relief needs the separate personal-return eligibility test. Annex **9D** identifies founders in **2–3**, transfers relief to **4**, and reconciles **5–7 totals to main 090/120/130**, which instruction 133 distributes equally between founders. Instruction **134** uses **income column 5 × tax-relief percentage** to calculate the corresponding relieved income in **8**; **135** expressly gives **9 = 5 − 8**. Column **10 = 6 − 7** gives tax after relief. These are different income and tax measures; the actual column-9 header has a missing subtraction operand, so use instruction 135 in the working paper and verify electronic acceptance. Columns 9/10 feed the personal return only where that founder has an article-83 filing obligation. [Instructions 15, 103–115, 130–136][ven12fullinstructions]; [actual annexes 3D/9D][ven12fullform]; [Code arts. 33–35, 83][code].

**Instalments and territorial allocation are separate schedules.** Annex **8D** offers the following period's estimated-tax or preceding-period-tax methods; for the ordinary calendar route each of its four printed dates receives one quarter of the selected statutory amount. Apply current article 84's agricultural/non-calendar routes and SME/IT-park/deferred-class exclusions instead of forcing every taxpayer into those four boxes. Annex **10D** applies to subdivisions outside the head office's administrative territory: enter subdivision code, locality code and tax allocation in columns **2–4**. Allocate using the preceding-period average employee count **or** preceding-period accounting income under current article 84(3), and reconcile the complete column 4 total to **main 170**, before instalments, rather than the cash balance in 190. Under instruction 140, a new subdivision has zero under the prior-period headcount method when it has no prior-period base; a liquidated subdivision receives the amount for its active quarters, excluding the liquidation quarter. No annex 10D is needed for the stated current-loss/absent-row 170 situation. As a positive ordinary check, main 150 of 24,000 less foreign credit 6,000 gives allocation base 170 of **18,000**; instalments 15,000 leave cash 190 of **3,000**. A 75%/25% prior-headcount split allocates **13,500/4,500**, totalling 18,000. Do not allocate the 3,000 cash balance. [Instructions 27–31, 129, 137–140][ven12fullinstructions]; [actual annexes 8D/10D][ven12fullform]; [Code art. 84][code].

Reconcile the approved current return to the general ledger, asset/loss/credit schedules and actual SFS account. Reconcile subdivision allocation under art. 84(3) to annex 10D above. Use the statute's special liquidation/reorganisation periods and deadlines where applicable. Filing instructions and portal access must come from the current approved form, not an old form label or bank description. [Arts. 54^4(5)–(6), 83–87][code].

## Penalties and interest

**Calendar-2026 ordinary tax late charge.** Code art. 228(3) and the BNM decision of 6 November 2025, point 1, supply the calculation: the retained **6.00%** short-term policy rate, rounded up to a whole percent, plus **5 percentage points**, divided by **365 days**, gives **0.0301% per delayed day** after rounding the daily percentage to four decimal places. The decimal multiplier is **0.000301**. Apply it to the established outstanding principal for each chargeable day; split changes in principal and calendar year. This calculation concerns debts governed by art. 228 and does not replace a separate statutory regime's rate or establish case-specific relief. [Code art. 228(2)–(3)](https://www.legis.md/cautare/getResults?doc_id=157050&lang=ro); [BNM decision, point 1](https://bnm.md/en/node/69226).

Late tax accrues from the day after its due date through actual payment inclusive. Article 228(3) sets the annual daily rate from the preceding November BNM short-term policy rate rounded up to a whole percentage point, plus 5 percentage points, divided by days in the year and mathematically rounded to four decimal places. Do not compound the debt automatically. Apply the actual account movements, statutory exceptions and the corrected-return cap in art. 228(2^1). [Art. 228][code].

For corporate taxpayers within art. 232(a), failure to follow return preparation/submission rules carries 500–1,000 per return, with the 10,000 total cap in art. 260(1). Understatement through false return data has the separate 20%–30% sanction; qualifying self-correction is excepted under art. 261(4^1). Evasion has its separate 80%–100% rule. Understatement in the art. 87(1^1) deferred-payment class has the specific 1,000–10,000 rule; distinguish its commencement/application from ordinary understatement. [Arts. 232, 260(1), (6), 261(4)–(5)][code]; [Law 41 arts. I(7), X(2)][amend].

Instalment underpayment has art. 261(6)'s own comparison with preceding-year tax and 80% of final current tax after the specified credits, its below-5,000 exception, dates and art. 228(5) exceptions. It is not an automatic percentage of every quarterly shortfall. Obtain the actual prior/current tax and credits before calculating a sanction. [Art. 261(6)][code].

## Cross-border points

A resident business's worldwide income is not a blanket exemption for foreign receipts. For art. 82 credit, obtain proof of actual payment/withholding certified by the competent foreign authority; translate to Romanian unless issued in English or Russian. Credit only Moldova's tax on the same income, in the period Moldova taxes it. Actual treaty entitlement and refund procedures require the operative treaty and residence/beneficial-owner facts. [Arts. 13–14, 82][code].

Separate company profit tax, dividend-related advance/deferred company tax and recipient withholding. Resident-individual dividends use art. 90^1's 6%/historic 15% split; nonresident dividends use art. 91's ordinary 6% and specified 15% exceptions. Nonresident interest/royalty payments require actual Moldova-source classification, treaty relief and the art. 91 exclusions; do not assert a universal reduced treaty range. PE-linked receipts and covered employment have separate routes. Use the cross-border Guide for the full source/PE/treaty method and the TP Guide for affiliated transactions. [Arts. 80^1, 90^1–92][code].

## Two worked examples that recompute

### 1. Ordinary company reconciliation, loss and foreign credit

Assume a resident ordinary company outside the special/deferral regimes. Accounting revenue is 1,000,000 and accounting expenses 700,000, including a nondeductible statutory fine of 5,000 and book depreciation 50,000. The separately verified asset schedule supports tax depreciation 40,000; this example does not determine asset lives. An unexpired earliest loss of 100,000 is fully usable under the origin-year schedule. The reconciled profit includes 50,000 of net foreign income taxable in Moldova at 12%, with certified qualifying foreign tax 8,000. No other adjustments/credits; evidenced instalments are 18,000. Taxable income is 215,000, tax 25,800, allowable foreign credit 6,000 and final balance 1,800. [Arts. 15, 26^1, 30, 32, 44, 82–87][code].

```oa-check
name: Moldova 2026 ordinary corporate loss and capped foreign credit
inputs:
  accounting_revenue: 1000000
  accounting_expenses: 700000
  statutory_fine: 5000
  book_depreciation: 50000
  verified_tax_depreciation: 40000
  eligible_unexpired_loss: 100000
  same_foreign_net_income: 50000
  certified_foreign_tax: 8000
  evidenced_instalments: 18000
steps:
  accounting_profit: accounting_revenue - accounting_expenses
  profit_before_losses: accounting_profit + statutory_fine + book_depreciation - verified_tax_depreciation
  taxable_income: max(0, profit_before_losses - eligible_unexpired_loss)
  gross_tax: taxable_income * 0.12
  foreign_tax_cap: same_foreign_net_income * 0.12
  allowed_foreign_credit: min(certified_foreign_tax, foreign_tax_cap)
  final_tax: max(0, gross_tax - allowed_foreign_credit)
  balance_due: final_tax - evidenced_instalments
expected:
  accounting_profit: 300000
  profit_before_losses: 315000
  taxable_income: 215000
  gross_tax: 25800
  foreign_tax_cap: 6000
  allowed_foreign_credit: 6000
  final_tax: 19800
  balance_due: 1800
```

### 2. Eligible SME accounting-income base

Assume the taxpayer has established eligibility, a timely 2026 SME election, no VAT registration/change and no prohibited consultancy/shareholding facts. The full-year financial-accounting income is 1,000,000 before recording current returns of 20,000, and includes 50,000 of verified art. 20 income and 10,000 of exchange-rate income. These exclusions do not overlap; no return has already been deducted. Ordinary operating expenses do not reduce this base. The resulting 920,000 base gives 36,800 tax at 4%; evidenced quarterly payments of 30,000 leave 6,800. [Arts. 54^1–54^4][code].

```oa-check
name: Moldova 2026 SME defined accounting income
inputs:
  accounting_income_before_returns: 1000000
  verified_article20_income: 50000
  exchange_rate_income: 10000
  current_returns_not_already_recorded: 20000
  quarterly_payments: 30000
steps:
  sme_income_base: accounting_income_before_returns - verified_article20_income - exchange_rate_income - current_returns_not_already_recorded
  annual_sme_tax: sme_income_base * 0.04
  balance_due: annual_sme_tax - quarterly_payments
expected:
  sme_income_base: 920000
  annual_sme_tax: 36800
  balance_due: 6800
```

## Ask the client first

- What is the legal/taxpayer category, residence, tax period, VAT registration history and elected tax regime? Supply the actual accounting policy and prior-year income/classification tests.
- Who holds participation/voting rights, in how many SMEs, and from which dates? What are the actual last-day employee, turnover/assets and activity figures for any deferral claim?
- Supply the trial balance, invoices, bank reconciliation, related-party contracts and all accounting-to-tax adjustments; identify private/exempt-income expenditure and benefits separately.
- Supply each asset's acquisition, commissioning, legal life, grant/lease/use history and disposal facts, plus loss-origin/utilisation schedules.
- Which foreign receipts, certified foreign taxes, treaties/residence evidence and distributions by profit-origin year exist? Supply instalments, withholding and company-tax payments separately.
- Supply the actual approved return, SFS account/notices, corrections and filing/payment receipts before concluding an outstanding liability or sanction.

## Sources

**Bounded source review, 31 October 2026.** The [independent review record](../../evidence/ledgers/md-country-evidence/independent-review/FINAL-REVIEW.md) covers the stated source/claim scope. Ordinary gaps below remain unresolved. This Guide remains a source-cited draft, without accountant attestation or comprehensive coverage.

Primary-source reads on 30–31 October 2026, with each date below.

| Official source | Selected reads and limits | Read |
|---|---|---|
| [BNM monetary-policy decision, 6 November 2025, point 1](https://bnm.md/en/node/69226) | Fetched 6.00% short-term base input; calendar-2026 daily percentage derived with Code 228(3), rather than copied from an old rate. | 2026-10-30 |
| [Fiscal Code, current 30 October consolidation][code] | Selected corporate scope, deduction, accounting, SME, credit, distribution, filing and enforcement articles cited above; ordinary browser body read after automated retrieval returned 403. No full-Code audit claimed | 2026-10-30 |
| [Fiscal Code, 1 January version][jan] | Art. 54^1 threshold and commencement notes | 2026-10-30 |
| [Fiscal Code, 27 March version][mar] | Art. 54^1 and Law 41 commencement; current rules compared with January and later versions | 2026-10-30 |
| [Law 41/2026, enacted March version][amend] | Art. I and X: SME threshold, instalment exclusion, corrected-election sentence and deferred-class sanction; later consolidated application still controls | 2026-10-30 |
| [Government Decision 693/2018, current annex 1][corpreg] and [January version][corpregjan] | Selected ordinary deduction procedures, cap/evidence methods, loss-origin and tax-payment rules; point 79 is incomplete in the rendered source and not adopted | 2026-10-30 |
| [Government Decision 321/2026][corpregamend] | Point 2.1 changes business-annex points 30–31 on 18 June; January Code already contains the membership/union alternative from 1 January | 2026-10-30 |
| [Government Decision 10/2012, current travel regulation][travelreg] and [amending Decision 783/2024][travelamend] | Ordinary travel authorisation, evidence, reimbursement, category, settlement and currency methods; actual annex-2 rates retained and read separately below | 2026-10-30 |
| [Government Decision 704/2019, 2025 consolidation][assetreg] | Per-asset basis/depreciation/repair/disposal methods and read historical-transition provisions; actual register/calculation annex fields now mapped below | 2026-10-30 |
| [Government Decision 941/2020, 2022 catalogue consolidation][assetcatalogue] | Life selection, minimum/manufacturer/used/unlisted cases and business commencement; five numeric class rows from the actual annex applied below | 2026-10-30 |
| [Actual travel-rate annex 2][travelrates] | Full five-page table and geographic footnote retained/read; stated destination/currency/category/lodging method applied | 2026-10-31 |
| [Actual asset-register annex 1][assetregister] and [repair annex 2][assetrepair] | All 29 register instructions and seven repair columns read and visually checked; units and carry-forward fields distinguished | 2026-10-31 |
| [Actual numeric life catalogue][assetlifetable] | Full binary retained; only five applied rows visually checked on pages 27/30/34, not every asset class | 2026-10-31 |
| [SFS-published VEN12 instructions][ven12instructions] and [form][ven12form], selected actual text | Main-return period/signature/reconciliation, ordinary cash-donation/undocumented cap working paper, loss/credit/payment rows, current representation-expense field route and unused capital annex. Selected parsed text only; historical S-election years are not adopted for 2026; the 360,000 gate is confirmed by current Code 33 | 2026-10-30 |
| [Actual linked SIMM form][simm24form] and [instructions][simm24instructions] | One-page form and both instruction pages downloaded, retained and visually read. Category-A row method supplied; printed SIMM24M/retired category-B mismatch and live portal/version handling remain explicit | 2026-10-30 |
| [MF Order 143/2024, enacted approval][simm24order] | SIMM24 approval, final SIMM20 year, 2024 first reporting year, publication commencement and early-obligation exception; actual linked form/instructions now retained and read below | 2026-10-30 |
| [MF Order 153/2017][ven12order] | VEN12 approval/consolidation and attachment references only at that earlier read; later full attachments separately recorded below | 2026-10-30 |
| [Actual full VEN12 form][ven12fullform] and [instructions][ven12fullinstructions] | Original DOC/DOCX retained unchanged; full text, all 17 form tables and all numbered instructions read; all 7+12 rendered pages visually inspected. Income/expense, donation, relief, foreign-credit, founder, instalment and territorial schedules mapped; inactive/historical fields and source defects explicitly separated. No portal test or independent approval | 2026-10-31 |
| [Current Code article 22][code] | Actual article body, excluding contents entry: forced loss, same-nature replacement, replacement basis and following-period limit | 2026-10-31 |
| [CNAS 2026 instructions][average] | Point 12.1 records the 17,400 forecast salary and Government Decision 773/2025; used only for that sourced input | 2026-10-30 |
| [Finance Ministry 2026 explanation][changes] | Corroborating new payment/deduction rules, not a substitute for the operative Code; January SME summary is superseded by Law 41 | 2026-10-30 |

Not yet confirmed: the actual ministry limits for the specified tobacco, ethyl-alcohol and petroleum losses under article 24(13); all 2026 commencement interactions beyond the selected transitions; current VEN12 portal acceptance, foreign-credit zero/loss and overlapping-relief allocation, current facilitation-classifier codes/operative incentive entitlements, the source-label/header defects and founder personal-return implementation, and current SIMM24 portal naming/obsolete-category handling, statutory sum-difference routing, rounding and filing/payment implementation beyond the now-read linked annexes; actual minimum domestic transport tariffs and remaining special personnel/trip cases beyond the sourced annex-2 rate/currency/category method; current meal-voucher nominal limit/scheme and any employee-benefit cases beyond the sourced transport/food, development and recreation methods; asset classes beyond the five applied catalogue rows, accelerated-method field implementation and historical-transition/capped-car implementation beyond the cited ordinary register/repair methods, and the final noncash donation-value/VAT/main-050 reconciliation, food-donation special regime or other special capped-base computations beyond the now-sourced donation field/ordinary cash-cap methods; the exact operational prorata rounding and corrected-election process for art. 87(1^1), including the denominator and applicable election rules for distributions from 2023–2025 origin profits; full specialist incentive/free-zone/IT-park/financial/reorganisation/liquidation methods; current treaty-by-treaty rates and procedures. The old unsourced universal treaty ranges of 0%–5% and 0%–10% are not certified rules. Actual facts, authorisations, notices and receipts remain required. The domain stays partial until ordinary gaps are resolved.

[code]: https://www.legis.md/cautare/getResults?doc_id=157050&lang=ro
[jan]: https://www.legis.md/cautare/getResults?doc_id=149766&lang=ro
[mar]: https://www.legis.md/cautare/getResults?doc_id=153668&lang=ro
[amend]: https://www.legis.md/cautare/getResults?doc_id=153667&lang=ro
[average]: https://cnas.gov.md/sites/default/files/2026-10/Particularitati2026.pdf
[changes]: https://mf.gov.md/ro/content/modific%C4%83rile-efectuate-%C3%AEn-codul-fiscal-pentru-anul-2026-privind-impozitul-pe-venit-tva

[corpreg]: https://www.legis.md/cautare/getResults?doc_id=154927&lang=ro
[corpregjan]: https://www.legis.md/cautare/getResults?doc_id=150441&lang=ro
[corpregamend]: https://www.legis.md/cautare/getResults?doc_id=154909&lang=ro
MF Order 145/2024, points 1–3: actual enacted VEN12 income/expense adjustment rows and commencement. Read 30 October 2026: https://www.legis.md/cautare/getResults?doc_id=146071&lang=ro.

MF Order 10/2024, points 1–2: enacted fixed-asset loss/donation row classification, separate book/tax columns and reporting commencement. Read 30 October 2026: https://www.legis.md/cautare/getResults?doc_id=141590&lang=ro.

[ven12assetamend]: https://www.legis.md/cautare/getResults?doc_id=141590&lang=ro
[ven12amend]: https://www.legis.md/cautare/getResults?doc_id=146071&lang=ro
[simm24form]: https://www.legis.md/UserFiles/Image/RO/2024/mo%20501%20ro/an_1_143_md.docx
[simm24instructions]: https://www.legis.md/UserFiles/Image/RO/2024/mo%20501%20ro/an_2_143_md.docx
[simm24order]: https://www.legis.md/cautare/getResults?doc_id=146028&lang=ro
[ven12instructions]: https://sfs.md/uploads/blank/210/document/instructiunepdf-6761280a94279.pdf
[ven12form]: https://www.sfs.md/uploads/blank/210/document/formularpdf-67612806009d2.pdf
[ven12order]: https://www.legis.md/cautare/getResults?doc_id=146095&lang=ro

[travelreg]: https://www.legis.md/cautare/getResults?doc_id=145854&lang=ro
[travelamend]: https://www.legis.md/cautare/getResults?doc_id=145826&lang=ro
[assetreg]: https://www.legis.md/cautare/getResults?doc_id=146665&lang=ro
[assetcatalogue]: https://www.legis.md/cautare/getResults?doc_id=131787&lang=ro

[travelrates]: https://www.legis.md/UserFiles/Image/RO/2023/mo502-504md/an2_10_md.docx
[assetregister]: https://www.legis.md/UserFiles/Image/RO/2020/mo%20372-382%20md/anexa%20nr_1_704.docx
[assetrepair]: https://www.legis.md/UserFiles/Image/RO/2019/mo400-406md/anexa%20nr_2_704.docx
[assetlifetable]: https://www.legis.md/UserFiles/Image/RO/2020/mo%20372-382%20md/anex%C4%83_941%20ro.docx

[ven12fullform]: https://www.legis.md/UserFiles/Image/RO/2024/mo%20506-508%20ro/an_1_153md.doc
[ven12fullinstructions]: https://www.legis.md/UserFiles/Image/RO/2024/mo%20506-508%20ro/an_2_153md.docx

## Today's figures and who stands behind this skill

This file is an AI skill (tax rules your AI follows) from OpenAccountants, copied on 2026-10-31. Rates, thresholds and deadlines change. For the current version of this skill, its official sources and the named accountant (if any) who stands behind it, call `get_skill` with slug `md-corporate-income-tax` on the OpenAccountants connector (https://www.openaccountants.com/connect), or read https://www.openaccountants.com/skills/md-corporate-income-tax. If neither is available, confirm every figure against the official source pages cited above before relying on it.