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Tax & Compliance 7 min read

MITP minimum tax per employee: how the floor calculation works

Moldova's MITP regime sets a per-employee floor of MDL 5,220 per month for 2026. When that floor exceeds 7% of turnover, it is the binding constraint. Here is the exact calculation every MITP company needs to know.

By
Incorpore Advisory
Role
Boutique Moldovan corporate practice
Published
24 May 2026

The 7% turnover figure attracts founders to the Moldova IT Park regime, and rightly so. What the headline rate does not communicate is the per-employee floor that governs low-revenue months and early-stage companies. Understanding this floor is, in practice, the most important piece of MITP arithmetic a new resident needs to master.

What the MITP floor is and why it exists {#what-the-mitp-floor-is-and-why-it-exists}

The Moldova IT Park (MITP) operates under Law 77/2016. The unified 7% tax replaces corporate income tax, personal income tax on salaries, employer and employee social contributions, medical insurance, real estate tax, road tax, and several local levies. The single rate is what makes the regime attractive; the floor is what keeps it honest.

Without a floor, a company could register one token employee, generate minimal payroll, and pay near-zero tax on turnover that may still be commercially significant. The floor prevents that. SFS — the State Fiscal Service — enforces a minimum monthly tax per employee equal to 30% of the forecast national average monthly salary for the relevant year. For 2026, that figure is MDL 5,220 per month, per employee.

The floor is recalculated annually by reference to the official forecast salary published by the Moldovan government. Founders planning multi-year models should build in a modest upward drift: the national average salary has risen each year, and the floor moves with it.

The MITP floor is not a penalty — it is the minimum contribution per seat that sustains the social and fiscal consolidation the regime provides.

How the calculation works {#how-the-calculation-works}

The MITP tax owed for any period is the greater of:

  • 7% of actual gross turnover for the period; or
  • MDL 5,220 × number of qualifying employees × number of months in the period.

"Number of qualifying employees" means employees who worked at least one calendar day during the period under a formal employment contract registered with the company. Part-time staff count as one employee for the floor calculation regardless of contracted hours. An employee who joins on the last working day of a month counts for that entire month.

The period is typically monthly, matching the MITP periodic filing cycle. The company declares its turnover, calculates 7% of that figure, then calculates the floor for the same period, and remits whichever is higher.

The 30% rule in practice. The MDL 5,220 figure is derived from the government's 2026 forecast average monthly salary of MDL 17,400, multiplied by 30%. Founders sometimes ask whether 30% refers to the actual salary paid to each employee; it does not. It is a statutory floor based on the national forecast average, entirely independent of what individual employees actually earn. An employee paid MDL 20,000 per month and an employee paid MDL 8,000 per month each contribute exactly MDL 5,220 to the floor calculation.

What "one day worked" means. The relevant criterion is whether the employee was under an active employment contract for at least one calendar day in the period. Leave, sick leave, and national holidays do not reduce the count; the employment contract must simply be in force and the employee must not be suspended or on an unpaid leave that takes them off payroll entirely for that month.

When the floor bites: low-revenue months and early-stage companies {#when-the-floor-bites}

The floor becomes the binding constraint whenever the product of headcount and MDL 5,220 exceeds 7% of turnover. The breakeven point per employee is straightforward: a single employee requires monthly turnover of at least MDL 74,571 before the 7% rate generates more tax than the floor (MDL 74,571 × 7% = MDL 5,220).

Early-stage companies face this arithmetic most acutely. A founder who registers the company, takes on two employees in month one, and bills MDL 60,000 in the first month owes the floor for two employees: MDL 10,440. The 7% of MDL 60,000 would have been MDL 4,200, but the floor governs.

The same logic applies seasonally. An established MITP company with four employees billing MDL 1.2M annually might average MDL 100,000 per month in turnover. At 7%, monthly tax is MDL 7,000. The four-employee floor is MDL 20,880. The floor dominates every month until turnover reaches MDL 298,286 per month — approximately MDL 3.6M annually — for that headcount.

This is not a defect in the regime; it reflects the reality that MITP was designed for genuinely operating IT businesses, not shells. The floor ensures every resident makes a minimum contribution proportionate to its employment footprint.

Worked example: three employees over four months {#worked-example}

Suppose an MITP-resident SRL has three employees throughout a four-month period and records gross turnover of MDL 500,000 across those four months.

Floor calculation:

MDL 5,220 × 3 employees × 4 months = MDL 62,640

Turnover-based calculation:

MDL 500,000 × 7% = MDL 35,000

The floor is MDL 62,640; the turnover tax is MDL 35,000. The company owes MDL 62,640 for the period.

To break even — that is, for the 7% rate to equal or exceed the floor with three employees over four months — the company would need turnover of at least MDL 894,857 over those four months (roughly MDL 223,714 per month). At MDL 1M in turnover for the period, the 7% rate (MDL 70,000) would exceed the floor (MDL 62,640) and the turnover-based figure would apply.

The practical takeaway: low-margin months in an otherwise healthy business rarely cause structural problems, provided the annual turnover is sufficient. The issue arises when a company builds headcount ahead of revenue, a common pattern in early-stage technology businesses.

Planning around the floor {#planning-around-the-floor}

Several practical responses are available once founders understand how the floor operates.

Timing employee headcount. Founding employees who join under formal contracts before commercial revenue is generating trigger the floor from day one. Where a founder is actively building the product before first revenue, it is worth modelling whether formal employment contracts — as opposed to consulting or service agreements with a holding company — should begin at formation or after the first revenue milestone is reached. The decision has substance and labour-law implications beyond tax, but the floor arithmetic should factor into it.

MITP versus standard CIT. For companies at an early stage with high headcount relative to revenue, the standard 12% CIT regime — combined with the 0% reinvested-profits scheme available to qualifying SMEs with turnover up to MDL 100M and up to 249 employees — may produce a lower effective tax burden than MITP during the build phase. The 0% rate applies to undistributed profit; tax only crystallises on dividend distribution at 12% CIT plus 6% withholding. For a pre-revenue or low-revenue company with genuine payroll costs, the CIT base is depressed by those costs, and the floor does not apply.

The comparison is not automatic. MITP brings payroll tax consolidation that the standard regime does not offer, and the simplification value is real. However, founders who enter MITP early with a large team and low initial revenues sometimes discover the floor creates a higher tax burden than the standard CIT route would have during the first twelve to eighteen months. Modelling both paths before formation is the correct approach.

A company that enters MITP the moment it has staff, without projecting the floor against forecast turnover, may pay more tax in year one than it would have under the standard CIT regime.

Monitoring the floor throughout the year. Finance teams should track the floor versus 7%-of-turnover comparison monthly, not annually. This allows timely adjustments: deferring a new hire by a month, accelerating a revenue milestone, or re-evaluating the structure if the floor persistently dominates. Monthly monitoring is straightforward once the MDL 5,220 figure is built into the management accounts.

For a complete explanation of the MITP regime — eligibility, qualifying activities, and the annual compliance cycle — see Moldova IT tax benefits: the 7% MITP regime and filing. For companies weighing MITP against the standard regime, Moldova's 0% reinvested profits tax sets out the alternative in full.

Next steps {#next-steps}

The MITP floor calculation is straightforward once the variables are clear: MDL 5,220 per employee per month, compared against 7% of actual turnover, with the higher figure owed. The planning work — matching headcount timing to revenue ramp, choosing between MITP and the standard CIT regime — is where founders benefit most from specialist input before the structure is set.

For more on company formation in Moldova and structuring options, see the company formation overview. Structuring questions — including the MITP versus standard CIT comparison — are addressed on the first advisory call before any documents are prepared.

Published 24 May 2026

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