Tax
Law

We assist with tax audits, challenge State Tax Service decisions and assess the tax implications of transactions in Moldova.

We review documents and assess potential losses.

Focus

What timely tax defence gives a business

Audit

Unexpected tax audit

SFS inspectors begin a deep audit of your operations, requesting massive volumes of primary documentation and summoning counterparties for cross-checks.

  • Procedural controlWe verify the legality of inspectors’ requests and actions.
  • Prepared documentationWe prepare responses and evidence for every disputed issue.
  • Preserving the positionWe prevent rushed explanations and uncontrolled signing.
Resolution

Additional tax assessments and fines

Following an audit, the tax service issued a decision to reassess VAT, income tax, and impose huge penalties threatening the company.

  • Review of calculationsWe analyse the report, primary documents and grounds for reassessment.
  • Challenge strategyWe prepare arguments for administrative and court defence.
  • Enforcement controlWe assess grounds for suspending enforcement of the decision.
Risk

High fiscal risk transactions

You are planning a complex transaction and need to assess the risks of double taxation and potential tax penalties.

  • A clear tax modelWe assess the tax effects of contracts and transaction structure.
  • International risk assessmentWe account for tax treaties and transfer-pricing issues.
  • Solutions before signingWe remove vulnerabilities while terms can still be changed.

Our tax law expertise

Our understanding of tax and court practice helps us build a well-reasoned position in complex tax disputes.

Challenging decisions (Tax Litigation)

When the audit act is already on the table and the business needs a challenge strategy.

Challenging decisions (Tax Litigation)

Administrative and judicial appeal of tax control acts, reassessment decisions, and penalty sanctions.

Business tax support

When transactions and tax requests already require an ongoing tax filter.

Business tax support

Ongoing tax consulting, preparing reasoned responses to SFS requests, evaluating tax consequences of contracts.

Moldova IT Park taxes

When an IT company needs to check residency, single-tax treatment, and contract-model risks.

Moldova IT Park taxes

We analyze whether the Moldova IT Park regime applies, the 7% single tax, contract structure, payroll, work with residents and non-residents, audit risks, and tax consequences of entering or leaving the regime.

Audit representation

When the audit has to be controlled from the inspector's first request.

Audit representation

Support during desk and on-site tax audits. Monitoring the legality of inspector actions, protecting documents.

International taxation

When the group already carries double-taxation and transfer-pricing risk.

International taxation

Consulting on the application of double tax treaties (DTT), transfer pricing.

Director liability protection

When the tax dispute is already starting to hit the director and accountant personally.

Director liability protection

Legal protection of directors and chief accountants from subsidiary and criminal liability for company tax offenses.

M&A tax structuring

When the deal has to be built so tax does not destroy the economics afterward.

M&A tax structuring

Minimizing tax losses during holding restructuring, mergers and acquisitions, and joint venture creation in Moldova.

Examples from practice

Court decisions speak louder than promises. Typical examples of protecting businesses from fiscal pressure.

Cancellation of multi-million VAT fines

A distribution company was reassessed over 3 million lei in VAT due to subcontractor bad faith.

What we did

We dissected the audit act, gathered proof of real operations, and drove the dispute to a full cancellation of the sanctions.

Result:

We proved the reality of operations and client's due diligence. The SFS decision was fully annulled.

Lifting of unjustified account seizure

The tax service blocked corporate accounts of a logistics company during a lengthy audit, paralyzing international shipments.

What we did

We launched an urgent challenge, showed the disproportionality of the measure, and quickly restored access to the accounts.

Result:

Through emergency judicial review, we obtained recognition of the seizure as disproportionate. Accounts were unblocked within 72 hours.

Transfer pricing dispute

A foreign holding was fined for allegedly artificially lowering prices when selling software to the parent company.

What we did

We brought in independent transfer-pricing expertise and built a strong pre-trial position against the sanctions.

Result:

We engaged independent international auditors for a Transfer Pricing File report and challenged the sanctions pre-trial. The pressure was lifted.

Preparing a position in a tax dispute

A strong position in a tax dispute is built before court proceedings begin. Our strategy is based on careful preparation of every relevant document.

Express problem audit

Express problem audit

We analyze the audit report or SFS decision together with your chief accountant. We evaluate the legality of the inspector's conclusions.

Stage outcome:

  • Report review
  • Breach map
  • Defense priorities

Prospect assessment

Prospect assessment

We study court practice of the Court of Appeal and Supreme Court of Justice. We honestly forecast the probability of overturning the act.

Stage outcome:

  • Case assessment
  • Legal position
  • Decision strategy

Suspension of enforcement and court proceedings

Suspension of enforcement and court proceedings

We assess the grounds for suspension and file the necessary applications.

Stage outcome:

  • Evidence
  • Applications
  • Suspension

Court representation

Evidence base collection

Filing a lawsuit in administrative court with a simultaneous motion to suspend the SFS decision (avoiding forced collection).

Stage outcome:

  • Expert analysis
  • Evidence file
  • Court position

Control and ongoing support

Implementation control

We monitor implementation, adjust documents in time and remain involved through the next stage.

Stage outcome:

  • Court defense
  • Enforcement control
  • Case management

The Colenco Legal team

Frequently asked questions

Short answers to what is usually worth clarifying before the first consultation.

When should tax counsel be involved even before an audit or dispute?

Short answer

Whenever there is already a risk of an audit, a sensitive transaction, reassessments, account freezes, or questions around the tax burden structure. The earlier the position and documents are assembled, the better the chances of keeping the issue out of crisis mode.

Can tax decisions still be challenged if the pressure has already started?

Short answer

In many cases yes, if the act, documents, calculations, and procedural failures are reviewed quickly and then a pre-trial and litigation line is built. What matters here is not emotion but a precise legal position built around numbers and procedure.

What should be brought to the first consultation on a tax dispute?

Short answer

Usually the audit report, tax decisions and notices, key primary documents, contracts, and a short explanation of where you see the risk or unfairness are enough. If the file is incomplete, work can still start from the current picture and defense priorities.

Confidential

Assess the risks of an audit or dispute

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  • Your enquiry is handled confidentially
  • We will contact you during business hours at the number provided

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