Moldova Clarifies VAT Treatment

Background to the guidance

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In late 2025, Moldova’s State Tax Service issued a series of clarifications on the application of value added tax to cross-border transactions, digital platforms and energy supplies. The guidance aims to eliminate uncertainty and align tax practice with updated VAT provisions under national legislation.

Resale of goods outside Moldova

The STS clarified that goods purchased by a Moldovan resident and resold abroad to a nonresident are not subject to Moldovan VAT. The decisive factor is the place where ownership is transferred. If the transfer of ownership occurs outside Moldova, the transaction is not considered a domestic supply and therefore falls outside the scope of Moldovan VAT. This clarification is particularly relevant for companies engaged in international trading operations without physical import into the country.

Freelance platform commissions treated as imported services

The tax authority also addressed commissions charged by international freelance services platforms. In October 2025, the STS clarified that such commissions, when billed to Moldovan legal entities, qualify as imported services. Since the place of supply is determined by the supplier’s head office or the beneficiary’s residence, these services are subject to the standard 20% VAT rate. In practice, this places the VAT obligation on the Moldovan recipient under the reverse-charge mechanism.

Electricity and gas: updated VAT registration rules

In 2025, the STS adopted Order No. 531, amending VAT registration documentation related to electricity and natural gas supplies. These amendments entered into force on January 1, 2026, and were introduced to align domestic procedures with revised VAT rules governing such supplies.

Mandatory registration before purchase

From the start of 2026, business entities that receive electricity or gas must register as VAT payers prior to purchasing these supplies. This change removes the ability to postpone VAT registration until certain turnover thresholds are reached and significantly affects tax compliance practices in the energy sector.

Expert takeaway from International Investment

As experts at International Investment note, Moldova’s VAT clarifications highlight a broader move toward tighter oversight of cross-border trade, digital services and regulated utilities. While the exemption for foreign resale reduces double taxation risks, stricter treatment of imported services and energy supplies increases the importance of proactive VAT compliance and structured tax planning.