US Company Formation from Moldova (2026): US LLC or C-Corp, Moldova IT Park's 7% Single Tax, Romanian Passports and the Soviet-Era Treaty

Moldova's IT sector has grown into one of the country's biggest exporters, much of it built around Moldova IT Park (MITP). Its single tax of 7% of turnover replaces corporate tax, payroll tax and social contributions for qualifying companies. Chișinău's developers and outsourcing firms work for clients in the USA, Western Europe and Romania. Many Moldovans also hold Romanian citizenship and an EU passport, which shapes how banks and clients see them.

A US company can be formed from Moldova remotely, and it can sit alongside an MITP company rather than replace it. This guide explains how the Moldovan regimes interact with a US company, what the old Soviet-era treaty means for payments from the USA, and how US LLC formation compares with US C-Corp formation.

In short: Moldovan citizens and residents can own 100% of a US LLC or C-Corporation, formed remotely. Moldova taxes residents on worldwide income. Personal income tax is 12% and dividends are taxed at 6%. Moldova IT Park residents pay a single 7% tax on turnover in place of most other taxes, with a minimum amount per employee, and at least 70% of revenue must come from eligible IT activities. The IRS treats the 1973 US–USSR treaty as applying to Moldova: interest and royalties from the USA are generally exempt from US withholding, but dividends stay at 30%. With UCB, a Wyoming LLC with EIN is $249 and a Delaware corporation with EIN is $358, all-in.

Who can form a US company from Moldova

Any person can own a US company, whatever their nationality or residence. A Moldovan citizen, a dual Moldovan–Romanian citizen, a foreigner living in Chișinău, or a Moldovan SRL (including an MITP resident) can own a US company outright. A single owner can be its only manager. There is no need for a US visa, SSN, US address or trip. The registered agent the company needs in its state is included for the first year in every UCB formation (see registered agent explained). The EIN comes from the IRS without an SSN or ITIN (see EIN for non-residents).

Which passport to use. If you hold both Moldovan and Romanian passports, use one of them consistently across the company documents, the EIN application and the bank application. The bank will also ask where you live, which is a separate question from citizenship. For proof of address, use a utility bill (Premier Energy, Apă-Canal, Moldtelecom or Orange) or a bank statement, translated if needed.

Residents of the Transnistrian region, which is outside the control of the Moldovan authorities, should expect US banks and payment providers to apply additional scrutiny or to decline. Use a registered address under Moldovan government control.

How Moldova taxes a US company and its owner

Moldovan tax residents are taxed on worldwide income:

• Personal income tax is a flat 12%.
• Dividends are taxed at 6%, the same rate for dividends from Moldovan and, as a rule, foreign companies.
• Corporate income tax is 12% under the general regime. Small companies can use a turnover-based regime.
• Foreign tax paid on foreign income can be credited, up to the Moldovan tax on it.

Moldova IT Park

MITP is a "virtual" park. A Moldovan company becomes a resident if at least 70% of its revenue comes from eligible IT activities such as software development, IT services and some outsourcing. In return it pays a single tax of 7% of turnover, which replaces:

• corporate income tax;
• personal income tax on employees' salaries;
• social and health contributions;
• several local taxes.

There is a monthly minimum per employee, linked to the average salary, which rose in 2026. The state has guaranteed the regime's main features for park residents, though how long the guarantee lasts has been described differently in different sources, so check the current position.

For a Moldovan IT business with US clients, MITP is often the most tax-efficient vehicle for the work itself. A US company adds a US contracting party and US payments. It should not take over the work, or the MITP company's revenue and its eligibility will suffer.

The treaty the IRS applies

There is no modern income tax treaty between the USA and Moldova. The IRS treats the 1973 convention with the Soviet Union as still in force for Moldova:

• Interest and royalties paid from the USA to a resident of Moldova are generally exempt from US withholding.
• Dividends are not covered, so US corporate dividends carry 30%.
• Business profits are taxed in the USA only through a permanent establishment there.

The royalty exemption can be useful for a Moldovan company that licenses its own software or IP to US customers or to its US subsidiary. Claim it on Form W-8BEN-E, and make sure the licence and its pricing reflect real IP owned in Moldova (see W-8BEN-E vs W-8BEN).

US LLC formation from Moldova

US tax treatment

The IRS looks through a single-member LLC with a non-resident owner and treats its income as the owner's. With the work done in Moldova, and no office, staff or contract-signing agents in the USA, the income is generally outside US income tax (see effectively connected income explained). The LLC pays no dividends, so the 30% rate does not apply. It must file Form 5472 with a pro forma Form 1120 every year, and missing it carries a $25,000 penalty (see Form 5472 explained).

A lei example

These are illustrative figures, not a client case, at MDL 17.5 to the dollar.

Ion runs a seven-person web development company in Chișinău that is an MITP resident. Two US agencies want a US subcontractor, so his company forms a Wyoming LLC as its contracting subsidiary.

In 2026 the LLC bills US$300,000. It pays the MITP company US$285,000 for the development work, about MDL 5 million, which counts towards the 70% eligible revenue. The MITP company pays 7% single tax on its turnover, about MDL 349,000, covering its payroll taxes as well. The LLC keeps US$15,000 for US insurance, travel and a sales commission.

In the USA, the LLC files Form 5472 and a pro forma 1120 and owes no income tax, because it has no US office or staff. In Moldova, the work is done and taxed in the MITP company. When Ion takes dividends from the MITP company, he pays 6%.

US C-Corp formation from Moldova

US tax treatment

A US C-Corporation pays federal tax of 21% on its own profits, plus state tax where it does business, and files Form 1120 and Form 5472 every year (see the 21% corporate tax explained and the C-Corp guide for non-residents). Its dividends to Moldova are withheld at 30%.

When it fits

• Start-ups raising venture capital, with a Delaware parent and the Moldovan team in an MITP subsidiary paid for development. The parent owns the IP and raises the money (see raising US investment as a foreign founder).
• A US sales subsidiary with US staff, which pays US tax on its US profit anyway.
• Co-founders split between Moldova, Romania and elsewhere. A corporation keeps the cap table clean.

Moldovans with Romanian citizenship

A Moldovan who also holds Romanian citizenship can use the Romanian passport for identity, and it often makes bank onboarding easier. It does not change tax. If you live in Moldova, you are taxed in Moldova. If you have moved to Romania or elsewhere in the EU, your new country's rules apply. Some EU countries treat a US LLC as a company rather than as transparent (see the Central and Eastern Europe guide).

Which state

• Wyoming or New Mexico for a contracting LLC run from Moldova.
• Delaware for any corporation raising investment.

See best state for non-residents and the state selector.

What it costs

UCB's formation prices include state fees and the first year of registered agent service:

• A Wyoming LLC with EIN costs $249, or $348 with a US bank account application.
• A Delaware corporation with EIN costs $358.

A Wyoming LLC costs $121 a year to keep active, or $421 including the annual federal return. A US business address with your own suite number is $60 a year. See what a US LLC costs every year.

Banking

US banks and fintechs generally accept Moldovan owners, especially those with an EU passport, after standard checks. What helps:

• A specific business description.
• An English website.
• Your MITP resident certificate if you have one.
• Matching names across documents.
• A US business address with your own suite number.

Transfers to Moldovan banks such as maib, Moldindconbank or OTP arrive as foreign currency payments, which the bank documents under the foreign exchange rules. See US business bank accounts for non-residents, why banks reject non-resident applications and Stripe for non-residents.

Common mistakes

• Moving the work into the US LLC, which reduces the MITP company's eligible revenue.
• Assuming the old treaty cuts dividend withholding. It does not; dividends stay at 30%.
• Mixing passports across documents.
• Using an address in the Transnistrian region for a US bank application.
• Missing Form 5472 in a year when no US tax was due.

Frequently asked questions

Can a Moldovan citizen own 100% of a US company? Yes, without visiting the USA or holding a US visa.

Can my MITP company own a US company? Yes. A common structure is an MITP company doing the work and a US company contracting with US clients, with arm's-length pricing between them.

Is there a US–Moldova tax treaty? The IRS applies the 1973 US–USSR treaty to Moldova. It generally exempts interest and royalties from US withholding, but dividends stay at 30%.

How does Moldova tax dividends from my US company? At 6%, with a credit for any US tax withheld.

Does my US LLC pay US tax? Not if it has no US office, staff or agents. It files Form 5472 and a pro forma 1120 every year.

How UCB can help

We handle US company formation from Moldova remotely: the state filing, EIN, registered agent, US business address and bank application. Each year we file the federal return through our US tax filing service. Your Moldovan accountant handles State Tax Service and MITP filings, and we supply the US records they need. See our formation, EIN and bank account package and the Ukraine guide for a regional comparison.

Setting up a US company from Moldova? WhatsApp us at +1 315 961 2956 or email enquiries@ucbsolutions.com.