12% VAT for HoReCa and 8% dividend tax: what changes for businesses in 2027

Law No. 247/2026, adopted on October 22 and published on October 31 in Official Gazette No. 543-544, sets the tax rules for 2027. For businesses, the most significant changes are the reduced 12% VAT rate for food services and accommodation, the 8% tax on dividends from profits generated in 2027, and the extension of the mechanism for deferring tax on undistributed profit.

The general effective date is January 1, 2027. There are exceptions: some provisions entered into force upon publication or on November 1, 2026, while some of the VAT rules for energy apply from April 1, 2027.

What the law published on October 31 provides

The act is based on the fiscal and customs policy package approved by the Government on September 8. In October, Parliament considered dozens of amendments. The Government’s opinion of October 15 shows which proposals were accepted. The figures in this article are those in the published law, not just those in the September 8 announcement.

12% VAT for HoReCa and some agricultural products

The standard VAT rate remains 20%. A reduced rate of 12% is introduced for food products accompanied by related services intended for immediate consumption under Section I of CAEM (Classification of Activities in the Moldovan Economy)—that is, food services—and for accommodation services. The same 12% rate applies to certain livestock, crop and horticultural products.

For a restaurant, moving from 8% to 12% changes the amount excluding VAT included in a bill. For example, on a 500 lei bill including VAT, at the 8% rate the restaurant keeps 462.96 lei excluding VAT. To keep the same net amount at the 12% rate, the bill would rise to 518.52 lei. If the price stays at 500 lei, the amount excluding VAT falls to 446.43 lei, a difference of about 16.53 lei per bill.

The reduced 8% rate remains in place for a narrower list of products, including some fresh vegetables and fruits. For cereals and oilseeds, the 8% rate applies until January 1, 2028. The September proposal to extend the 8% rate to eggs and poultry meat was removed from the draft through amendments accepted in October.

Cash registers, menus and invoices must be updated from the first day the new rates apply. An incorrect rate on a receipt is immediately visible during an inspection.

Undistributed profit: deferral until 2029 and a 200 million lei threshold

Businesses with no more than 249 employees and turnover or total assets of up to 200 million lei may defer payment of tax on income calculated from the profits of the 2027, 2028 and 2029 tax periods until the 25th day of the month following the month in which they paid dividends or covered losses from previous years. The eligibility threshold was 100 million lei.

The mechanism defers payment until distribution; it is not a permanent exemption. When the profit is distributed as a dividend or used to cover losses, the related tax becomes due.

Dividends from 2027 profits taxed at 8%

The withholding tax rate on dividends remains 6% for profits generated through the end of 2026. For dividends distributed from profits generated starting in the 2027 tax period, the rate is 8%. Dividends earned by resident individuals from sources outside the country are also taxed at 8%.

Example: on 100,000 lei in dividends from 2027 profits, the tax is 8,000 lei, compared with 6,000 lei at the previous rate. For profits accumulated before 2027, the rate applicable upon distribution remains the one set for those profits. The decision to distribute or reinvest is best made based on records for each year, not a single rate.

Other measures affecting businesses

• Legal entities conducting financial and insurance activities (Section K of CAEM) apply an 18% income tax in 2027 only.

• Peasant farms are to apply the 12% rate, aligning them with individual enterprises, according to the draft retained by the Government after rejecting the amendment that called for the differentiated rate to remain.

• The special 4% turnover regime has been revised. In the draft approved by the Government, the threshold for income from business and management consulting above which the regime no longer applies was reduced from 60% to 25%.

• A special VAT regime and a 12 lei handling fee per parcel, paid by the recipient, apply to distance sales of imported goods worth up to 150 euros per parcel. These provisions began to apply on November 1, 2026.

• Tax arrears of up to 20 lei per economic classification are automatically canceled.

Administrator’s checklist

This list does not replace the text of the law or consultation with the company’s accountant. Some implementation details, particularly recordkeeping for profit by year and qualification for special regimes, depend on the forms and instructions of the State Tax Service.