Moldova published Order No. 21 of 11 March 2025 in the Official Gazette on 14 March 2025, establishing rules for the country’s new transfer pricing regime.
The Order No. 21 of 11 March 2025 amends Order No. 9 of 26 January 2024. A key change is the addition of an annex with detailed rules for Advance Pricing Agreements (APAs).
Starting 1 January 2025, unilateral, bilateral, and multilateral APAs will be introduced. The new annex outlines the submission, examination, finalisation, amendment, reporting, verification, termination, and fee payment for APAs.
Deadlines for resolving APA requests are six months for unilateral, 12 months for bilateral, and 18 months for multilateral APAs, with the possibility of extensions.
Additionally, the amendments clarify transfer pricing file requirements and allow submission in paper or electronic format. If the transfer pricing file is submitted in electronic format, it needs to be signed electronically by the respective person or persons with responsible positions.
