Moldova Tax Optimization

---
name: moldova-tax-optimization
description: "Compare legally available Moldova tax regimes and owner extraction for 2026. Covers actual IT-park status and permitted activities, cumulative seventy-percent eligibility, the monthly sales base and employee minimum, included and separate taxes, annual verification, entry and exit, ordinary income tax, the eligible four-percent SME regime, dividends and employment classification. Use for Moldova tax planning, IT Park seven-percent tax, minimum per employee, non-IT revenue, small-business regime, SRL versus individual entrepreneur, dividend versus salary and a single-client contractor. This source-cited draft corrects unsupported savings and blanket prohibitions and states remaining form, procedure and case-specific gaps. A bounded source-review record is linked under Sources; accountant attestation remains pending."
license: "AGPL-3.0-or-later (code) / OpenAccountants Guide License v1.0 (content)"
metadata:
  source: openaccountants
  openaccountants_url: "https://www.openaccountants.com/skills/moldova-tax-optimization"
  jurisdiction: "MD"
  tax_year: "2026"
  last_updated: "2026-10-31"
---

# Moldova tax planning and regime comparison, 2026 v0.8

## Who this applies to

Use this Guide to compare an ordinary Moldovan business, the eligible non-VAT small-business regime and an actual IT-park resident, and to evaluate company distributions and genuine independent work. Establish legal eligibility before comparing amounts. An SRL, an individual entrepreneur and the new registered independent service entrepreneur are different legal/tax populations; an invoice or a software-related description does not select a regime. This is a source-cited draft, with stated implementation gaps and a bounded source-review record linked under Sources. [Code arts. 13–15, 24(11^1), 54^1–54^4, 88, 368][code]; [Law 77/2016 arts. 2, 7–8][park].

Read the connected [corporate](md-corporate-income-tax.md), [individual](moldova-income-tax.md), [payroll](moldova-payroll.md), [social/medical](moldova-social-contributions.md), [VAT](moldova-vat.md), [formation](md-company-formation.md) and [cross-border](md-cross-border.md) methods for the actual taxpayer. Do not present a savings range or a universal best entity as a verified result: no fetched primary source establishes those savings for an identified population.

## Rates, bands and thresholds

| Item | Verified 2026 rule/input | Primary source |
|---|---|---|
| Ordinary company or individual-entrepreneur income tax | **12% of the applicable taxable-income base**; the legal person and individual have different deductions/procedures | [Code art. 15(a)–(b)](https://www.legis.md/cautare/getResults?doc_id=157050&lang=ro) |
| Eligible SME accounting-income regime | **4% of the article-54^2 base**, not profit and not a general option for every small freelancer | [Code arts. 54^1–54^3](https://www.legis.md/cautare/getResults?doc_id=157050&lang=ro) |
| IT-park monthly single tax | Greater of **7% of monthly accounting sales revenue** and the statutory monthly employee minimum | [Code arts. 369–371](https://www.legis.md/cautare/getResults?doc_id=157050&lang=ro) |
| IT-park employee minimum | **30% × 17,400 = 5,220 MDL** for each employee counted under article 369(2) for the month | [Code arts. 369(2), 370(2)](https://www.legis.md/cautare/getResults?doc_id=157050&lang=ro); [enacted Government Decision 773/2025](https://www.legis.md/cautare/getResults?doc_id=152066&lang=ro) |
| IT-park main-activity test | At least **70%** permitted-activity sales revenue, measured cumulatively each month from the statutory start; conditional relief for at most **two calendar months** | [Code art. 368(2)–(3)](https://www.legis.md/cautare/getResults?doc_id=157050&lang=ro); [Law 77 art. 2](https://www.legis.md/cautare/getResults?doc_id=143443&lang=ro) |
| Ordinary dividend to a resident individual | **6%** withholding; the specified undistributed **2008–2011** profits use **15%** | [Code art. 90^1(3^1)](https://www.legis.md/cautare/getResults?doc_id=157050&lang=ro) |
| Ordinary domestic nonresident dividend withholding | **6%**, with the specified **15%** historic-profit/capital rules; actual treaty relief needs its own evidence | [Code art. 91(1)](https://www.legis.md/cautare/getResults?doc_id=157050&lang=ro) |
| IT-park insured salary basis | **68% × 17,400 = 11,832 MDL** monthly under the stated rule; this is distinct from the 5,220 tax minimum and actual cash salary | [Law 77 art. 16(1)](https://www.legis.md/cautare/getResults?doc_id=143443&lang=ro); [Government Decision 773](https://www.legis.md/cautare/getResults?doc_id=152066&lang=ro) |

The independent-service and independent-retail regimes are different populations from an ordinary individual entrepreneur. For an **eligible registered service entrepreneur**, the single tax is **15% of its defined income base up to 1.2 million MDL**, and **35% only on the excess**. The statutory tax composition and annual medical allocation/top-up must be checked separately; “single tax” does not certify that no further amount can arise. For **eligible independent retail excluding excise goods**, the income-tax rate is **1%**, with the ordinary full-year **3,000 MDL minimum** and specific cessation/cash-register rules. Current article 69^13(3) limits that retail route to persons registered before **1 July 2026**; do not present it as an unrestricted new-entry option in October. The full amendment/commencement history remains a stated gap. Use the [individual](moldova-income-tax.md) and [social/medical](moldova-social-contributions.md) methods, actual registration and activity conditions before comparing either regime. [Code arts. 69^6–69^13, 69^20–69^26][code].

The IT-park forecast-wage input comes from the enacted decision, not a draft or the prior year's 16,100 figure. This is not an independent review or a whole-Code audit. [January Code][jan]; [current Code][code].

## The base

### Establish IT-park status and the real eligible activity

Law 77 defines a resident as a Moldovan-registered business person entered in the park's resident register and carrying out a permitted main activity under a contract with its administration. The registered person signs that contract, enters the register on signing and receives the prescribed status confirmation. Article 7 provides a contract of at least **four years**, within the park's lifetime, and contractual provisions including activities, reports and the mandatory membership contribution. A generic SRL or IT invoice is not evidence of park status. Obtain the actual registration/contract and applicable dates; the complete Government registration-form procedure and current membership-fee amount remain unverified here. [Law 77 arts. 2, 7][park].

Law 77 article 9(2) sets a **20-year maximum** for a park’s operation; the actual term is fixed by its Government creation decision. This maximum and the resident contract’s four-year minimum are different clocks. The Moldova park’s actual creation/extension decision and end date remain unverified here; do not turn the statutory ceiling into a guaranteed twenty-year individual tax holiday. [Law 77 art. 9][park].

The current article-8 list is broader than software development but has precise restrictions. Match the real service, contract/deliverable and applicable classification; a broad CAEM heading alone does not prove every activity within it qualifies. [Law 77 art. 8(a)–(r)][park].

| Permitted main-activity category | Classification and limiting condition in article 8 |
|---|---|
| Custom software, game publishing, other software publishing | **62.01, 58.21, 58.29** respectively |
| Computer-facility management, data processing/hosting, web portals, IT consultancy, other IT services | **62.03, 63.11, 63.12, 62.02, 62.09** respectively |
| Other education | **85.59**, limited to computer training |
| Natural-science/engineering R&D | **72.19**, using specialised high-performance computing and limited to the listed **72.19.11, .12, .13, .21, .29 and .50** services; retain the statute's biotechnology exclusions |
| Biotechnology R&D | **72.11**, limited to the described bioinformatics and nanobiotechnology research/development |
| Electronic components/modules | **26.11**, limited to microprocessors and integrated circuits |
| Postproduction special effects/animation | **59.12**, specialised high-performance computing; limited to **59.12.14 and 59.12.15** |
| Specialised design | **74.10**, using specialised high-performance computing |
| Game-industry postproduction | **59.12**, exclusively for computer games and limited to digital colour correction/restoration **59.12.13** and sound editing/design **59.12.17** |
| Game-industry audio/music | **59.20**, exclusively for computer games, limited to original sound recordings **59.20.13** |
| Contact centres | **82.20**, technology/customer-channel based, exclusively for export, including the stated freight procurement/logistics customer relations |
| Other workforce provision | **78.30**, computer/electronic/technical/software mediated, exclusively for export; limited to listed IT/telecom HR **78.30.11**, other administrative HR **78.30.12** and the described freight procurement/logistics/customer-relations personnel |

For each month, divide eligible article-8 service/work sales revenue by total product/goods/service/work sales revenue. Use year-to-date figures for a continuing resident, or figures from the start of the special regime for a new resident that year. Exactly **70%** passes the threshold. The at-most-two-month relief in article 368(3) requires the relevant full-year/special-period ratio also to reach 70%; do not assume a temporary shortfall is harmless before the full condition is established. [Code art. 368(2)–(3)][code].

**AUDIT FLASH POINT** The old blanket statement that all non-IT revenue is prohibited is not the statutory method. Article 368 tests the permitted main-activity share; article 369 taxes the actual monthly sales base. Keep genuine other sales in the denominator/base as required, test the cumulative condition and do not relabel ineligible work as eligible. A revenue mix that fails the actual status conditions engages article 378. [Code arts. 368–369, 378][code]; [Law 77 arts. 8, 18–19][park].

### Calculate the single tax and the charges it does not replace

Determine monthly sales revenue under SNC/IFRS, including the actual accounting treatment, rather than using profit, all bank credits or a cumulative annual tax base. Returns/discounts reduce the base in the period of the return/discount, including those relating to prior-period sales. Count employees who worked, took paid leave or were in another situation that would generate insured income under the standard regime for at least **one day** under an employment contract during the month. Use that established statutory count; do not invent an FTE or salary-percentage reduction of the monthly minimum. Calculate `max(monthly_sales_base × 7%, counted_employees × 5,220)` for the ordinary 2026 case. [Code arts. 369–371][code]; [Government Decision 773][wage].

Article 372(1) includes business income tax, salary income tax, employer compulsory social contributions, employee compulsory medical premiums, local taxes, immovable-property tax and the stated domestic-registered-vehicle road-use tax. The tax does **not** absorb VAT, excise, the other stated road charges, dividend/non-salary withholding, covered contributions on non-salary payments or other obligations not expressly included. Ordinary civil-service payments and owner dividends are not converted into covered salary merely because the payer is a park resident. Keep the actual administration contribution, verification/audit costs and other separate obligations in any comparison. [Code arts. 367(4), 372][code]; [Law 77 arts. 7(3), 15(1)–(1^1), 18][park].

Under article 376, accounting fixed-asset records continue although the special tax-depreciation calculation is not required during the regime; non-sales income has its stated single-tax treatment, special-regime losses are not later carried into the ordinary article-32 loss computation, and the registered individual park-business income has the stated personal-return exclusion. Do not extend those rules to every personal receipt. Covered park salary is finally taxed, without chapter-4 salary exemptions/deductions for that period or transferring the unused relief to a spouse. Employees must receive the written explanation required by Law 77 article 16(3). [Code arts. 376–377][code]; [Law 77 art. 16][park].

### Compare the 4% SME and ordinary systems using their real bases

Apply the [corporate Guide's SME eligibility/election method](md-corporate-income-tax.md) before comparing. Article 54^1 excludes VAT-registered taxpayers, peasant farms, individual entrepreneurs and the specified consultancy-heavy businesses whose prior-year CAEM **70.22** service share is above **60%** of sales. The election/mandatory-general supply tests use **1.5 million MDL through 26 March 2026** and **1.7 million from 27 March**, together with the actual prior-31-December supply categories and the **over-50%** exempt-without-credit condition in the relevant election route. These are not a universal SME turnover ceiling. No-prior-income/new-entity routes, the **over-25% in more than three SMEs** ownership rule and VAT entry/exit dates have their own conditions. Preserve the accounting-policy choice and actual regime period. [Code arts. 54^1–54^1/1][code]; [January Code][jan]; [Law 41/2026 arts. I, X][march].

The 4% base is the defined financial-accounting income, reduced for current returns/discounts and excluding article-20 income and exchange/sum differences. Ordinary operating expenses do not reduce this SME base. Ordinary 12% tax instead uses the legally reconciled taxable-income base, deductions, losses and credits. The arithmetic break-even `4% × SME_base = 12% × ordinary_taxable_base` is a comparison under established assumptions, not a legal right to choose either regime or a total-cost conclusion. Payroll, VAT, fees, payment timing, distributable profit and owner tax can change the result. [Code arts. 12, 14–15, 24, 32, 54^1–54^4][code].

### Distinguish salary, dividends and genuine independent work

An SRL dividend is a distribution of legally available net profit, not a substitute label for every payment to a working owner. Establish the members' decision, distributable profits/losses/reserves, paid contributions, creditor restrictions and solvency. Interim dividends require the prescribed interim financial statements and sufficient funds. The default payment period is **30 days after the decision**, unless the permitted different term applies. Keep company tax, any article-80^1 current-profit advance or article-87 deferred company tax, and recipient withholding separate. The ordinary resident-individual **6%** is applied to the dividend after company tax under the assumed ordinary case; historic profits and other recipient populations need their actual rule. [Law 135 arts. 39–40][srl]; [Code arts. 12(3), 15, 20(z^19), 80^1, 87, 90^1–92][code].

Salary requires the actual employment/remuneration, cumulative PIT, medical and employer-category social methods in the [payroll Guide](moldova-payroll.md). For the new independent-service entrepreneur, Code 88(8) specifically tests the counterparty conditions in article 24(11^1); it is not a general one-client test for every individual entrepreneur. Non-business individual service income and administrator mandates have article 88(5)–(6)'s rules. Labour Code article 2(3) applies labour legislation where a court finds that a civil contract actually regulates employment; article 45 identifies work for and under an employer's authority and the associated obligations. Record the actual work/control/contract facts. The old automatic single-client warning is not a certified numerical classification rule or a promise that single-client work is safe. [Code arts. 24(11^1), 88][code]; [Labour Code arts. 2(3), 45, operative 28 October 2026][labour].

## Deadlines and filing

| Obligation | Verified rule | Primary source |
|---|---|---|
| IT-park single tax | Compute/report and pay monthly by the **25th of the following month**; approved electronic form and actual headquarters treasury allocation | [Code art. 373(1)–(2), (4)][code] |
| IT-park related-party single-tax adjustment report | By the **25th of the sixth month** after the relevant article-12^1 fiscal period | [Code art. 373(1^1)][code] |
| Park salary information to SFS | Annually by **25 January** following the payment year | [Code art. 374(1)(a)][code] |
| Park salary information to employee | By **1 March** following the covered payment year; retain the stated months/amounts | [Code art. 374(1)(b)][code] |
| Other park reporting | Separate payroll/non-salary and excluded-tax reports remain required under their actual rules | [Code art. 374(1)(c), (2)][code] |
| Annual park eligibility verification | Required if the special regime was used for at least **one month**; performed by an audit entity under the prescribed indicator verification | [Law 77 art. 18][park] |
| SME regime | Quarterly payments by the following month's **25th**; annual return by **25 March** | [Code art. 54^4(2)–(3)][code] |
| Ordinary company tax and dividend withholding | Use the [corporate Guide](md-corporate-income-tax.md) and actual distribution/recipient dates; they are separate liabilities | [Code arts. 80^1, 83–87, 90^1–92][code] |

IT-park entry/exit changes the tax regime from the **month after** status acquisition/withdrawal. For salary accrued under one regime and paid under the other, retain the mechanism applicable at accrual when calculating/paying income tax and medical premiums at payment. Do not tax the same covered special-regime salary twice or assume ordinary-regime accrual becomes exempt solely because payment was later. [Code art. 375][code].

### Complete the actual monthly IU17 return

The current Order 135 consolidation and all nine linked official DOCX attachments have now been read and retained unchanged, including all fourteen rendered pages. Its annex 2 completion instructions are published inline in the official order and were read there. The May 2026 amendment supplies the current monthly-sales wording; keep it separate from the January 2026 form change. [Current Order 135 and inline annex 2][parkorder]; [Order 59 point 2][iuamend]; [attachment/read-scope evidence](../../evidence/ledgers/md-country-evidence/itpark-current-attachments.json).

Use the registered name/fiscal code, CAEM-2 activity, actual park registration code, four-character head-office CUATM, SFS office and submission date. The monthly period format is **L/NN/YYYY**, with month 1–12. This monthly period code does not replace the separate annual IUPT code or the annual salary-information year. Establish resident status and the applicable entry/exit month before selecting the return. [Order 135 annex 2 part I points 1–8][parkorder]; [actual IU17 header][iu17actual]; [Code arts. 368, 375][code].

| IU17 field | Working-paper method |
|---|---|
| 010 column 3 | Current-month accounting sales from account 611 under SNC/IFRS, with the applicable statutory returns/discounts treatment. Do not substitute profit, all cash receipts or cumulative sales. |
| 010 columns 5–6 | Printed **7%** rate; calculated turnover tax in 6 = column 3 × column 5. Column 4 is marked unused for this row. |
| 020 columns 3–6 | Actual qualifying employee count in 3, reporting-year forecast average wage in 4 and printed **30%** in 5; minimum tax in 6 =3 × 4 × 5. One qualifying insured/work/paid-leave day counts under the statutory test; do not invent an FTE reduction. |
| 030 column 6 and control sum | Larger of 010 column 6 and 020 column 6. The form's control sum is that same 030 column 6 amount. |

Sources: [actual IU17 form][iu17actual]; [current annex 2 part I points 9–12][parkorder]; [Code arts.369–371][code]. For a **2026** period, the established forecast-wage input is **17,400**, giving **5,220** per counted employee. Instruction 10's phrase referring to the wage in force when completing a return does not authorise substituting a later year's wage into an earlier reporting-year correction: Code 370(2) and the form's own header identify the reporting year. A late/corrected-period implementation must retain that year's legal input. [Code 370(2)][code]; [HG773/2025][wage]; [actual IU17 column 4][iu17actual].

For an assumed ordinary eligible month with sales **200,000** and three counted employees, 010 gives **14,000**,020 gives **15,660**, and 030/control sum is **15,660**. If another month has no sales but the same three counted employees, its minimum remains **15,660**; do not suppress it because turnover is zero. This arithmetic assumes status and the statutory employee population are established; it does not settle an actual eligibility breach or validate a zero-sales eligibility denominator. [Code 369–371][code]; [actual IU17][iu17actual]; [annex 2 I 9–11][parkorder].

**Eligibility annex: monthly and cumulative columns are different from the monthly tax base.** Row 1 contains total sales tied to main 010 column 3; row 2 contains sales of the actual Law 77 article 8 permitted services/works; row 3 is **row 2 ÷ row 1 × 100**. Column 3 is the reported month; column 4 is year-to-date for an existing resident, or from application of the special regime for a new resident in that year. Reconcile both columns independently. For example, monthly eligible sales 140,000 of total 200,000 give **70%**, while cumulative eligible 650,000 of total 1,000,000 give **65%**. A passing monthly percentage does not establish the cumulative condition; apply the Code 368 full-period and conditional two-month rules above. Do not invent a 0/0 percentage or assume it establishes eligibility. [Actual IU17 annex][iu17actual]; [Order 135 annex 2 part II points 1–4, including 1^1][parkorder]; [Code 368][code].

**Keep the 2025/2026 changeover separate.** Order 106, published **28 October 2025**, removes monthly IU17 rows **011/012** and their old instruction points **9^1/9^2** from **1 January 2026**; its new general related-party return and instructions also take effect on that date. The separate **IUPT24** annexes are the **2024** route; the general annex 7 form is actually labelled **IUPT25** and contains an explicit 2025 bridge for adjustments previously reported monthly. Do not restore the removed monthly rows or count the same TP adjustment twice. The [TP Guide's actual IUPT field method](md-transfer-pricing.md) supplies the annual reconciliation and its specific unresolved floor/refund cases. The [payroll Guide's actual ISAPTI17 and employee-information method](moldova-payroll.md) supplies the separate annual salary outputs; those are not the IPC21 insured-income base or another 7% payroll charge. [Enacted Order 106 points 1–8][park106]; [actual IUPT25][iupt25actual] and [2024-specific form][iupt24actual]; [Code 373–375][code].

Keep head-only or the authorised two-signature route, electronic submission receipt, actual payment/treasury reconciliation and corrections for the relevant regime/year. Actual attachments do not establish portal acceptance, park registration/contract, verification compliance, membership fees or a refund right. [Order 135 annex 2 I12][parkorder]; [Code 373–374][code]; [Law 77 arts.7,18][park].

## Penalties and interest

If the actual status conditions are breached, article 378 recalculates the resident's covered tax/social/medical obligations under the standard regime from the breach month, at the resident's expense, without recalculating the employees' obligations. Article 378(3) expressly disapplies article 228 in that breach case. For late **single-tax payment**, article 378(4) instead selects the annual social-budget late-charge rate; Law 320/2025 article 4 supplies **0.1% of debt per delayed day for 2026**. Do not substitute the ordinary 0.0301% article-228 tax rate for that specific park rule. Fines are separate from single tax and use the prescribed classification. [Code art. 378][code]; [Law 320/2025 art. 4][socialbudget].

Annual verification and Law 77 article 19's withdrawal grounds, notice/cure and court-challenge routes also matter. Do not convert the conditional two-month revenue test into permission to ignore false reporting, unpaid liabilities or other residency conditions. Ordinary SME, payroll, withholding and company-tax penalties retain their own provisions and case-specific exceptions. [Law 77 arts. 18–19][park]; [Code arts. 368, 378][code].

## Cross-border points

Law 77 article 7(4) permits the stated remote work in Moldova and/or abroad; it does not establish exemption from another country's payroll, permanent-establishment or residence rules. Test actual foreign work/management, customer/source facts, associated-party pricing, dividend recipient and treaty evidence through the [cross-border](md-cross-border.md) and [transfer-pricing](md-transfer-pricing.md) Guides. Export-only conditions in article 8(q)–(r) must be established for those activities; a foreign invoice alone does not prove every required fact. [Law 77 arts. 7–8][park]; [Code arts. 71–79^3, 91, 373(1^1)][code].

## Two worked examples that recompute

### 1. IT-park eligibility and the 2026 employee minimum

Assume current park status, qualifying activities, established cumulative eligible sales of 490,000 MDL and total sales of 700,000, with all other residency conditions met. The ratio is exactly 70%. For the current month, accounting sales are 100,000 and two employees each satisfy article 369(2)'s counted-employee rule. Seven percent gives 7,000; the employee minimum is 2 × 17,400 × 30% = 10,440, so the monthly single tax is **10,440 MDL**. Fees, excluded taxes, employee insured salary basis and any earlier balances are separate. [Code arts. 368–372][code]; [Government Decision 773][wage].

```oa-check
name: Moldova 2026 IT park cumulative eligibility and binding monthly floor
inputs:
  cumulative_eligible_sales: 490000
  cumulative_total_sales: 700000
  monthly_sales_base: 100000
  counted_employees: 2
  forecast_wage: 17400
  minimum_fraction: 0.30
  single_tax_rate: 0.07
steps:
  eligible_share: cumulative_eligible_sales / cumulative_total_sales
  minimum_per_employee: forecast_wage * minimum_fraction
  employee_minimum: counted_employees * minimum_per_employee
  revenue_tax: monthly_sales_base * single_tax_rate
  single_tax: max(revenue_tax, employee_minimum)
expected:
  eligible_share: 0.70
  minimum_per_employee: 5220
  employee_minimum: 10440
  revenue_tax: 7000
  single_tax: 10440
```

### 2. Ordinary profit/dividend tax versus an assumed eligible SME alternative

Assume the two legal alternatives have actually been established for the relevant period. Accounting income/SME base is 1,000,000 MDL and ordinary taxable income and pre-company-tax accounting profit are both 100,000. There are no returns, exempt/FX items, loss/credit adjustments, deferral or interim-tax complications. After paying company tax, all available profit can lawfully be distributed to a resident individual from non-historic profits, with no reserve/solvency restriction. In the ordinary case, company tax is 12,000; the 88,000 dividend has 5,280 withholding, leaving **82,720**. In the SME case, company tax is 40,000; the 60,000 dividend has 3,600 withholding, leaving **56,400**. These are assumed base/distribution comparisons, not proof that either regime or full distribution is available, a salary substitute, or a total saving including other taxes/fees. [Code arts. 15, 54^1–54^4, 90^1(3^1)][code]; [Law 135 arts. 39–40][srl].

```oa-check
name: Moldova 2026 ordinary versus eligible SME tax and lawful dividend extraction
inputs:
  sme_accounting_base: 1000000
  ordinary_taxable_income: 100000
  accounting_profit_before_company_tax: 100000
  ordinary_rate: 0.12
  sme_rate: 0.04
  dividend_rate: 0.06
steps:
  ordinary_company_tax: ordinary_taxable_income * ordinary_rate
  ordinary_gross_dividend: accounting_profit_before_company_tax - ordinary_company_tax
  ordinary_dividend_tax: ordinary_gross_dividend * dividend_rate
  ordinary_owner_net: ordinary_gross_dividend - ordinary_dividend_tax
  ordinary_combined_tax: ordinary_company_tax + ordinary_dividend_tax
  sme_company_tax: sme_accounting_base * sme_rate
  sme_gross_dividend: accounting_profit_before_company_tax - sme_company_tax
  sme_dividend_tax: sme_gross_dividend * dividend_rate
  sme_owner_net: sme_gross_dividend - sme_dividend_tax
expected:
  ordinary_company_tax: 12000
  ordinary_dividend_tax: 5280
  ordinary_owner_net: 82720
  ordinary_combined_tax: 17280
  sme_company_tax: 40000
  sme_dividend_tax: 3600
  sme_owner_net: 56400
```

## Ask the client first

Obtain these six groups of facts:

- legal form/registrations and regime dates; actual products/services and CAEM/CSPM restrictions.
- park status/contract, monthly and cumulative eligible/total sales, returns and counted-employee evidence; membership/verification costs.
- VAT status and prior-year supply mix; consultancy/ownership/SME tests and election policy.
- actual ordinary taxable income, accounting profit, contributions/reserves/losses and distributable cash; owners' residence/type and profit-origin years.
- paid work, mandates and independent-service counterparty/control facts; foreign work/management and associated transactions.
- accepted filings and outstanding debt.

Model the legally available choices using those numbers before presenting a saving.

## 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.

Read 30 October 2026. The bounded source-review record is linked under Sources; accountant attestation remains pending.

| Primary source | Scope actually read | Read date |
|---|---|---|
| [Current Fiscal Code][code] and [January Code][jan] | Full selected articles 367–379 in both versions; existing selected SME, company/individual, withholding and worker provisions retained in connected ledgers; no whole-Code verification | 2026-10-30 |
| [Law 77/2016, current operative consolidation][park] | Definitions/status/contract, complete article-8 activity list, incentives, employee social/medical rules, annual verification and withdrawal articles | 2026-10-30 |
| [Enacted Government Decision 773/2025][wage] | Actual 17,400 forecast-wage input for 2026; no proposal used | 2026-10-30 |
| [Law 135/2007 current arts. 39–40][srl] | SRL net-profit distribution, interim statements, decision/payment/creditor and solvency conditions | 2026-10-30 |
| [Labour Code, operative 28 October 2026][labour] | Articles 2/45 civil-contract/employment test; future December and later versions not used | 2026-10-30 |
| [Law 41/2026][march] | SME threshold change and selected connected commencement provisions already retained in corporate evidence | 2026-10-30 |
| [Order 59/2026 point 2][iuamend] | Directly read monthly IU17 accounting-sales amendment, not all form attachments | 2026-10-30 |
| [Social budget Law 320/2025 art. 4][socialbudget] | 2026 daily 0.1% input selected by Code article 378(4) for late single-tax payment | 2026-10-30 |

| [Current Order 135/2017, inline IU17 instructions][parkorder] and [enacted Order 106/2025][park106] | Full current inline instructions and actual amendment read: monthly period/base/count, separate cumulative eligibility, removal of monthly TP rows and January 2026 commencement. Nine linked original DOCX files/all 14 rendered pages read; actual IUPT and salary methods are in the TP/payroll companions. Source/portal ambiguities remain explicit | 2026-10-31 |

**Not yet confirmed:** full Government park registration/contract/application and indicator-verification instructions, actual current membership fee; authenticated IU17/ISAPTI/employee-information and IUPT correction/validation, salary-month cross-regime reconciliation, IUPT minimum/partial-year/equality/refund-floor implementation beyond the actual fields now mapped in the companion Guides; every taxpayer-specific revenue/accounting classification, withdrawal/re-entry/penalty/credit allocation and historical transition; full implementation of the corporate deferral option and the named SME/ordinary return implementation gaps; all independent-worker case law, sector authorisations, foreign payroll/social/treaty consequences and other incentive schemes. The old 20–50% saving, universal non-IT prohibition, automatic single-client reclassification and blanket “6% instead of salary” proposition are not certified. Their topics are retained in the sourced comparison/conditional methods or these gaps. Complete topic mapping is not comprehensive country coverage or independent review.

[code]: https://www.legis.md/cautare/getResults?doc_id=157050&lang=ro
[jan]: https://www.legis.md/cautare/getResults?doc_id=149766&lang=ro
[park]: https://www.legis.md/cautare/getResults?doc_id=143443&lang=ro
[wage]: https://www.legis.md/cautare/getResults?doc_id=152066&lang=ro
[srl]: https://www.legis.md/cautare/getResults?doc_id=153674&lang=ro
[labour]: https://www.legis.md/cautare/getResults?doc_id=155518&lang=ro
[march]: https://www.legis.md/cautare/getResults?doc_id=153667&lang=ro
[iuamend]: https://www.legis.md/cautare/getResults?doc_id=154274&lang=ro
[socialbudget]: https://www.legis.md/cautare/getResults?doc_id=156540&lang=ro

[parkorder]: https://www.legis.md/cautare/getResults?doc_id=154298&lang=ro
[park106]: https://www.legis.md/cautare/getResults?doc_id=151376&lang=ro
[iu17actual]: https://www.legis.md/UserFiles/Image/RO/2025/mo544-546ro/an_1_135md.docx
[iupt25actual]: https://www.legis.md/UserFiles/Image/RO/2025/mo544-546ro/an7_135md.docx
[iupt24actual]: https://www.legis.md/UserFiles/Image/RO/2025/mo544-546ro/an9_135md.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 `moldova-tax-optimization` on the OpenAccountants connector (https://www.openaccountants.com/connect), or read https://www.openaccountants.com/skills/moldova-tax-optimization. If neither is available, confirm every figure against the official source pages cited above before relying on it.