Moldova - Local Requirements – Aibidia

Source:

Tax Code of the Republic of Moldova (Law No. 1163-XIII of 24 April 1997), Title V, Chapter 11², as introduced by Law No. 356 of 29 December 2022, and as amended by Law No. 214 of 31 July 2024 and Law No. 187 of 10 June 2025
Order of the Minister of Finance No. 9 of 26 January 2024 on the approval of transfer pricing implementation rules (published in the Official Gazette on 9 February 2024), as amended by Order No. 21 of 11 March 2025 and Order No. 8 of 15 January 2026

Summary of local requirements

Strict Format: Not specified

Language: Romanian, English, Russian

To download the legislation in the original language, go to:

Transfer Pricing File (Local File)

The file on transfer prices will contain the following data and documents:

1.	Information about the taxpayer: a) the organizational, legal, and operational structure of the taxpayer; b) the list of affiliated persons, including branches/permanent establishments and their identification data, the geographical location of the affiliated persons; c) specification of the taxpayer's direct and indirect affiliation relationships
2.	General description of the taxpayer's/payer's activity, presentation of the main sales markets, pricing policy, as applicable
3.	Main competitors
4.	Description of the controlled transactions carried out with each affiliated person and the context in which they are carried out, including: a) description of the object of the transactions, including physical characteristics, quality, country of origin and of the producer, presence of a trademark, and other information related to the characteristics of the transaction object; b) description of transactions related to any business restructurings, in the period for which the transfer pricing file is prepared; c) description of transactions consisting of intra-group services, respectively presentation of cost allocation, as applicable, with individualization of services that contribute significantly and decisively to the creation of added value; d) description of transactions involving cost contribution arrangements
5.	Copies of all agreements/contracts related to the controlled transactions
6.	Functional analysis and detailed comparability analysis of transfer prices in controlled transactions
7.	Description of the method for establishing transfer prices for each transaction and justification of the selection criteria for it
8.	In the case of selecting transfer pricing methods that involve selecting the tested party, the justification for selecting it will be presented
9.	Description of the selected comparable uncontrolled transactions (internal and/or external), if applicable, and information about the relevant economic-financial indicators of profitability or margin/result/price of the transactions of independent companies on which the transfer pricing analysis is based, including a description of the methodology for searching comparables and the source of this information
10.	Calculation of the comparability interval
11.	Description of any comparability adjustments made and indication of the adjustments made to the results of the tested party and/or to the comparable uncontrolled transactions
12.	Description of the reasons for which it was concluded that the prices of the relevant transactions were established at arm's length based on the application of the chosen transfer pricing method
13.	Copies of the information, legal acts, documents that formed the basis for carrying out the controlled transactions.

Recommendations for Local File

Regarding content requirements:

Affiliated Person and Group Structure Disclosure:

Moldova requires detailed disclosure of both direct and indirect affiliation relationships, the full list of affiliated persons — including branches and permanent establishments — and their identification data and geographical locations.

We recommend documenting the full legal and ownership structure — including all affiliated persons and their locations — in the Ownership tab of the Legal Entities section.
Intra-Group Services and Cost Allocation:

Moldova requires a description of transactions consisting of intra-group services, including the presentation of cost allocation methodologies and the identification of services that contribute significantly and decisively to value creation.

We recommend documenting all significant intra-group service arrangements — including cost allocation bases and value-contributing services — in the Service Arrangements tab of the Service Arrangements section.
Cost Contribution Arrangements:

Moldova requires a description of transactions involving cost contribution arrangements.

We recommend documenting all cost contribution arrangements — including parties, scope, and allocation keys — in the Service Arrangements section, and uploading the corresponding agreements in the Legal Agreements section.
Copies of All Intercompany Agreements:

Moldova requires copies of all agreements and contracts related to the controlled transactions.

We recommend uploading all relevant intercompany agreements in the Legal Agreements section and mapping each agreement to the corresponding controlled transaction.
Comparability Interval Calculation:

Moldova explicitly requires documentation of the calculation of the comparability interval.

We recommend documenting the arm's length range — including the interquartile range or full range calculation and its statistical basis — in the Reason for concluding that transaction is at arm's length column in the Arm's Length Validations tab of the Economic Analysis section, and including the underlying calculations in the benchmark study uploaded to the Benchmarks & Comparables section.
Supporting Documents and Legal Acts:

Moldova requires copies of all information, legal acts, and documents that formed the basis for carrying out the controlled transactions.

We recommend saving all supporting documents and legal acts in the Resources section for attachment to the Local File.

Regarding format/structural requirements:

There is no strict format mandated, but all outlined data elements must be covered. The Local File must be prepared in Romanian only. Supporting documentation (e.g., copies of contracts, legal acts, and agreements underlying the controlled transactions) submitted upon request by the State Tax Service may be provided in their original language; however, documents in any language other than English or Russian must be accompanied by a Romanian translation prepared by an authorised translator.

We recommend preparing the Local File using TPDoc's standard Local File functionality, ensuring it is maintained contemporaneously and available for submission upon request by the State Tax Service. Use TPDoc's AI translation functionality to produce the final Local File in Romanian to meet local language requirements.

Principal File (Master File)

The transfer pricing file shall contain the following data and documents:

a)	Legal and ownership structure of the group and geographical location of its constituent entities.
b)	General description of the group's business: Narrative description of the key factors influencing the group's profitability; Description of the value chain within the group; List and description of significant intra-group services; Principal geographical markets for products/services; Description of the main functions performed, risks assumed, and assets used at the group level; A description of the most significant restructurings, acquisitions, and disposals of business activities within the multinational group that result in a change or reallocation of functions, assets, and risks occurring during the fiscal year.
c)	Description of intangible assets: General strategy regarding intangible assets (development, ownership, exploitation) and the location of principal research and development/portfolio management activities; Identification of relevant intangible assets (patents, trademarks, trade names, know-how, etc.) and their legal owner; List and description of significant agreements relating to intangible assets; Concise functional analysis regarding DEMPE (development, enhancement, maintenance, protection, exploitation); Transfer pricing policies for intangible assets, including research and development and the allocation of related profits; Significant intra-group transfers of intangible assets during the fiscal year (entities, countries, assets, conditions, compensation).
d)	Description of intra-group financial activities: General description of the multinational group's intra-group financing policies, including the principal financing provided to group companies by independent entities and the transfer pricing policies applied to intra-group financing; Identification of entities performing the centralised financing function, indicating the country in which they are located and the country from which their management functions are effectively exercised.
e)	Financial and tax positions of the group: Consolidated financial statements of the group for the reporting period, or their equivalent, or financial information extracted from the group's consolidated financial statements for the reporting period, including at least indicators such as total consolidated turnover, operating profit (or loss), and relevant segmented information pertaining to the taxpayer's activities; List and brief description of advance pricing agreements and other relevant tax rulings concerning the allocation of income between countries/states."

Recommendations for Master File

Regarding content requirements:

Moldova's Master File content requirements are closely aligned with the OECD BEPS Action 13 Master File structure. TPDoc's standard Master File functionality covers all required sections.

Regarding format/structural requirements:

Moldova does not prescribe a strict standardised template for the Master File. The Master File must be submitted within the deadline specified in the State Tax Service's request, and may be prepared in Romanian, English, or Russian.

We recommend preparing the Master File using TPDoc's standard Master File functionality, ensuring it is maintained contemporaneously and available for submission upon request by the State Tax Service.