Withholding tax · Codul Fiscal art. 901
Moldova dividend WHT, treaty or domestic.
Moldova withholds 6% on dividends as a domestic baseline. A residency certificate plus an applicable treaty can reduce that, sometimes to 5%. Choose the recipient, see what is actually withheld.
A current-year residency certificate from the recipient's home tax authority must be filed with SFS before the payment date to access a treaty rate.
Withholding tax
€0
Applicable rate
6% domestic
Net to recipient
€0
After Moldovan withholding
With vs without certificate
Treaty rates table
| Country | ≥ 25% holding | Other |
|---|---|---|
| Germany | 5% | 15% |
| Netherlands | 5% | 15% |
| Italy | 5% | 15% |
| Switzerland | 5% | 15% |
| United Kingdom | treaty status post-Brexit unclear; 6% domestic shown | same |
Where the treaty rate is higher than 6%, the domestic 6% applies; Moldovan WHT cannot exceed the domestic rate.
Methodology and assumptions
- Domestic dividend WHT: 6% under Codul Fiscal al RM, art. 901 alin. (31).
- Treaty rates: as per the bilateral double-tax treaties between Moldova and each listed jurisdiction. Most EU treaties grant 5% for corporates holding at least 25% of the payer's capital, 10–15% otherwise.
- Residency certificate requirement: original or apostilled certificate of fiscal residence from the recipient's tax authority for the year of payment, filed with SFS before withholding. Absent the certificate, 6% domestic applies regardless of treaty.
- UK: post-Brexit treaty status is operationally settled at the 6% domestic level pending administrative clarification. Confirm before relying.
- Home-country credit: the recipient's home jurisdiction generally grants a foreign tax credit for Moldovan WHT against domestic tax on the same dividend. Quantum varies and is not modelled here.
- Excluded: anti-avoidance scrutiny, beneficial-ownership challenges, transparency/CRS reporting, transfer-pricing on capitalisation.
What this does not do
Numbers are illustrative. Confirm specific figures with your Moldovan adviser before relying on them. The tool does not model the recipient's home-country credit, beneficial-ownership tests, anti-treaty-shopping rules, or CRS reporting obligations.
Plan your year-end distribution
with a senior adviser.
We file the residency certificate, run the home-country credit numbers, and tell you whether to distribute now or reinvest.