On 23 September 2026, Moldova’s Parliament adopted legislative amendments granting taxpayers the explicit right to request the resolution of tax disputes through administrative channels before resorting to court proceedings. The new provisions, introduced in the Tax Code and the Administrative Code, aim to reduce the burden on courts and accelerate the settlement of fiscal disagreements between the State Tax Service and businesses. The law enters into force on 1 January 2027, providing a six-month transition period for the tax authority to establish procedural regulations.
Key Takeaways
- Pre-litigation Administrative Review: Taxpayers can now file a formal request with the State Tax Service to review disputed tax decisions within 30 days of notification, suspending enforcement actions during the review.
- Mandatory Response Timeline: The tax authority must issue a reasoned decision within 45 days, extendable by 15 days for complex cases, failing which the taxpayer may escalate directly to court.
- Cost Reduction and Certainty: The mechanism is expected to lower litigation costs for SMEs and improve tax certainty by encouraging early settlement of disputes over VAT refunds, corporate income tax assessments, and transfer pricing adjustments.
Disclaimer: This article is compiled and summarized by the AI based on publicly available information and is for general information purposes only. It does not constitute any form of formal tax advice, legal opinion, or basis for performance. Please consult a qualified professional tax advisor or legal counsel for tax advice.
Source: Read Official Announcement