IT Parks in the Republic of Moldova

Transcription

1 Ministry of Economy and Infrastructure of the Republic of Moldova IT Parks in the Republic of Moldova Guide for Residents and Investors Chisinau 2018

2 IT Parks in the Republic of Moldova Guide for Residents and Investors Project Partners: Ministry of Economy and Infrastructure of the Republic of Moldova The Moldovan Investment and Export Promotion Organization (MIEPO) Moldova Competitiveness Project, financed by the USAID and Government of Sweden Moldovan Association of Information and Communications Technology Companies (ATIC) Text editing: Anatolie Pîrlii Design: Petru Cruc This publication was developed for the Moldova Competitiveness Project, financed by the United States Agency for International Development (USAID) and Swedish International Development Cooperation Agency (Sida). The contents are the responsibility of creator and do not necessarily reflect the views of USAID, the United States Government or the Government of Sweden.

3 Photo credit: PhotoStocks ABBREVIATIONS: ATIC - Moldovan Association of Information and Communications Technology Companies ICT - Information and Communications Technologies G.D. - Government Decision SMEs - Small and Medium-sized Enterprises MIEPO - The Moldovan Investment and Export Promotion Organization FDIs - Foreign Direct Investments GDP - Gross Domestic Product RM - Republic of Moldova Rstp - Resident of Science and Technology Park UE - European Union USD - US dollars

4 CONTENTS CHAPTER CHAPTER CHAPTER CHAPTER INTRODUCTION USEFUL CONCEPTS GENERAL PROVISIONS Legal Framework 1.2 Institutional Framework PROCEDURES FOR CREATION OF IT PARKS 2.1 Requirements for Subjects of IT parks 2.2 Documentation for Creation of IT Parks 2.3 Procedures for Creation of IT Parks 2.4 Administration of IT Park RESIDENTS OF IT PARKS. 3.1 Who can be resident of IT park 3.2 Resident-Administrator Relationship 3.3 Monitoring of Activity 3.4 Withdrawal of the Title of Resident BENEFITS OF THE STATUS OF RESIDENT 4.1 General Overview of the Tax Regime of Residents of IT Parks 4.2 Reporting and Payment of the Single Tax. Reporting of Other Information 4.3 Transition from Standard Tax Regime to Special Tax Regime 4.4 Consequences of Non-Compliance with the Special Tax Regime 4.5 Features of Taxation of Employees of Residents of IT Parks 4.6 Benefits of the Tax Regime Applicable to Residents of IT Parks I II III IV CAPITOL CHAPTER V ÎNCETAREA ACTIVITĂȚII TERMINATION OF ACTIVITY PARCULUI OF IT CAPITOL V ÎNCETAREA ACTIVITĂȚII PARCULUI ANNEXES

5 INTRODUCTION This Guide describes the conditions for: I. Creation of an information technology park; II.Obtaining the status of resident of an information technology park. The Guide also contains useful information on the benefits of the status of resident of an information technology park. * The general goal pursued by the state by adopting a legal framework for creation of IT parks, is ensuring favourable conditions for boosting competitiveness of the ICT sector. * The special goal is to create an IT park geared to boost development of the IT sector by creating high-value jobs and attracting domestic and foreign investments. Objectives of creating an IT park: * Increasing competitiveness of IT companies; * Supporting small and medium-sized enterprises engaged in the IT industry; * Attracting foreign and domestic investments; * Making businesses that create high-value added products; * Development of IT production; * Establishing partnerships with multinational IT companies with a view to convey positive practices and the most advanced knowledge in the field; * Attracting qualified human resources; * Creating jobs. This Guide has been developed for companies engaged in information technologies. 2

6 USEFUL CONCEPTS Administration of park - administrative authority established by the Government to manage an information technology park; Information technology park (park) - organizational structure, whose residents are engaged in activities provided for in Art. 8; Resident of park - a legal entity or an individual registered in the Republic of Moldova as subject of entrepreneurial activity that is included in the Register of Residents of Park and whose main activity is one or several activities provided for in Art. 8, based on a contract with the Administration of park; Main activity - activity that brings 70% or more of income from sales of resident 4

7 CHAPTER I GENERAL PROVISIONS LEGAL FRAMEWORK The legal framework on IT parks can be conventionally divided into two areas of interest/application: I. Legal framework on organization and functioning of IT parks; II.Legal framework on tax regime of residents of IT parks. Laws and Government Decisions: Law no. 77 of on Information Technology Parks; Law no. 145 of on Completion of Some Legislative Acts; Law no. 121 of on Completion of Some Legislative Acts; G.D. no. 254 of 14 May 2015 on Approval of the Strategy on Increasing Competitiveness of the Information Technology Industry. I. Legal Framework on Organization and Functioning of IT Parks; In terms of priorities, the concept of Information Technology Park (its core objectives) has become relevant through the following public policy documents: 1. Constitution of the Republic of Moldova. of , (Official Gazette of the Republic of Moldova, No. 1, ) The Constitution of the Republic of Moldova stipulates that the State shall ensure inviolability of investments of individuals and legal entities, including foreign ones. Thus, the concept of IT Park is geared to create favourable conditions for attraction of domestic and foreign investments. 2. The policy document Rethink Moldova' provides for the followings: R Unlike the region, Moldova has a poor performance in terms of adoption of electronic services, due to a weak strategy on the information system, unequal distribution of access to the Internet across the country and limited integration of information technology and communications in various sectors; R Development of the IT sector slows down due to shortage of qualified labor force; R Development of the IT sector is hampered by the lack of a coherent strategy on development and promotion of the industry. 5

8 3. National Development Strategy Moldova 2020" Law no. 166 of 11 July 2012 (Official Gazette of the Republic of Moldova, 2012, no , Art. 791) In terms of business: Clear game rules/ Strategic Vision' section states that the Republic of Moldova aims to improve conditions for activity of the business environment so that by 2020 the risks and costs associated with each stage of the business life cycle are lower than in the countries of the region, being governed by the principle of free competition. The impact of improved business environment will entail higher investments, higher number of functional enterprises encouraged to implement innovations, able to create attractive jobs, to ensure high productivity, effect sustained by progress of the Republic of Moldova in the international Doing Business' rankings, the Global Competitiveness Index, the Index of Economic Freedom and the Logistics Performance Index, as described below. 4. ICT Policy White Paper National Association of Private ICT Companies (ATIC), 2012/2013 The publication encompasses the vision and recommendations of the private sector to effectively improve the business environment for the ICT sector. The White Paper portrays the current situation of the ICT sector and outlines the actions for its continuous development and transformation of the country's economic growth into the driving force. The emphasis is also put on improving the tax and administrative environment (decreasing the share of informal ICT activities, simplification of the tax regime), boosting sustainable growth of the local ICT market (market volume, quality of ICT product, involvement of labor force, etc.), development of educational/human resources, etc. 5. National Strategy for Information Society Development Digital Moldova 2020" Government Decision no. 857 of 31 October 2013 The Strategy highlights the core issues of the ICT industry, which are themselves opportunities to build a digitized society and a position of a competitive country in both the region and worldwide. The basis for building the country's developed future is the ICT industry with its innovation and development opportunities, where entrepreneurs and government institutions increase as much as possible use of government data for the benefit of citizens. Digital Moldova 2020' aims creation of conditions through minimal intervention of the state, but with maximum effect for development of the information society. 6

9 CHAPTER I GENERAL PROVISIONS 6. Strategy for Increase of Competitiveness of the Information Technology Industry Government Decision no. 254 of 14 May 2015 (Official Gazette of the Republic of Moldova, 2015, No /291) The Strategy envisages interventions on Development of the infrastructure for innovative businesses and entrepreneurship' by creating at least one IT Park' offering tax and economic incentives geared towards development of IT start-ups, high-performance IT companies and innovative ideas. The main emphases are put on improving the business environment (creation of IT Parks, tax incentives for ICT companies, facilitation of access to the labor market for qualified and innovative staff Start-up Visa). 7. Action Programme of the Government of the Republic of Moldova for the years , includes a series of actions: Multi-sectoral implementation of the National Strategy for Information Society Development Digital Moldova 2020"; Creation of conditions for development and capitalization of the national digital content; Increasing digital literacy, development of digital competencies and digital inclusion; Creation of conditions required to boost competitiveness of the IT industry on both regional and international levels by adopting the Law on IT Industry Parks and the Sectoral Strategy on Increase of Competitiveness of the IT Industry; Re-engineering of existing processes of public service delivery in order to provide them electronically; Creation of an IT Centre of Excellence, in partnership with multinational companies and donors. 7

10 8. National Action Plan for Implementation of the Moldova-EU Association Agreement for the years (p. 63 measure 37, p.224 measure 4). In terms of long-term strategic objectives, the National Development Strategy Moldova 2020' is focused, among other development priorities, on improving the business climate, promoting the competition policy, optimizing the regulatory framework and applying information technologies in public services for business environment and citizens. Besides, we can say that the Moldovan Government insists on creation of a framework favourable for development of the IT sector, including by developing sectoral documents, such as: The National Strategy for Information Society Development Digital Moldova 2020, which aims at ensuring a regular and predictable development of the country, based on the principles stated in the Digital Agenda for Europe 2020". Strategic Program of Modernization of Governance (E-Transformation), approved by the Government Decision no. 720 of 20 September The Strategy for Increase of Competitiveness of the Information Technology Industry was the basis for approval of the Law no. 77 of on information technology parks and subsequently development and approval of the Law no. 145/2017. The Strategy for Increase of Competitiveness of the Information Technology Industry was the basis for approval of the Law no. 77 of on information technology parks and subsequently development and approval of the Law no. 145/2017. The Strategy for Increase of Competitiveness of the Information Technology Industry describes measures and actions aimed at improving the business environment and refer to the need to develop a legislative framework for creation and activity of IT parks, tax incentives for IT companies, simplification of access to the labour market of qualified and innovative human resources. The last measure was undertaken by approving the Law no. 121 of on Completion of Some Legislative Acts. This law completed the Law no. 200 of 16 July 2010 on the regime of foreigners in the Republic of Moldova and the Law no. 180-XVI of 10 July 2008 on labour migration, and created legal preconditions for issue of long-stay visas for persons with senior management positions of a legal entity engaged in IT activity and IT specialists within the technology information park. Through the Law no. 77 of on Information Technology Parks, the Parliament of the Republic of Moldova adopted for the first time in the Republic of Moldova the legal framework governing creation and activity of information technology parks. 8

11 CHAPTER I GENERAL PROVISIONS Information Technology Park is an organizational structure, whose residents carry out activities governed by Art. 8 of the Law on Information Technology Parks. Thus, one or several main activities* shall be carried out in IT parks included in to the Classification of Activities in the Moldovan Economy (CEAM Rev.2): A. customized software development activities (customer oriented software) (62.01); B. computer game editing activities (58.21); C. editing of other software products (58.29) D. management activities (management and operation) of computing means (62.03); E. data processing, web page management and related activities (63.11); F. web portal activities (63.12); G. information technology consulting activities (62.02); H. other information technology service activities (62.09). * The main activity is the activity, which brings 70% or more of income from sales of the resident of IT park. In order to determine fulfilment of the obligation on performance of the main activities allowed in the IT park, the ratio between the amount of income from sales of services, works allowed in the park according to Art. 8 of the Law on Information Technology Parks, and the total amount of income from sales of goods (commodities), provision of services, execution of works, income included in the accounting records. In this case, both indicators relating to the amount of income from sales are measured on a monthly basis, as an aggregate total from the beginning of the calendar year concerned or from beginning of the activity in the information technology park. Failure to reach the main activity indicator during at most any 2 calendar months of the current calendar year is not considered a violation of the legal provisions, provided that the indicator of 70% calculated as a whole for the year concerned is achieved. 9

12 LEGAL FRAMEWORK II. Legal Framework on Tax Regime of Residents of IT parks. By the Law no. 145/2017 a series of completions and amendments were made to: the Tax Code of the Republic of Moldova no. 1163/1997; the Customs Code of the Republic of Moldova no. 1149/2000; the Law no. 1585/1998 on Compulsory Health Insurance; the Law no. 489/1999 on the Public Social Security System; the Law no. 1593/2002 on the Amount, Procedure and Terms of Payment of Compulsory Health Insurance Premiums; the Law no. 289/2004 on Allowances for Temporary Incapacity for Work and Other Social Security Benefits; * By completing and amending the laws above, a special tax regime has been created for residents of IT parks. This tax regime for residents of IT parks refers to both a special regime for business resident of IT park and salary income of its employees. Order of the Ministry of Labour, Social Protection and Family no. 22 of on approval of the Classification of Occupations in the Republic of Moldova (CORM 00614);3 Decision of Chisinau Municipal Council no. 8/11 of on approval of Tariffs of Public Drinking Water Supply, Sewerage and Waste Water Treatment services, 4 provided by the JSC Apa-Canal Chisinau' ; G.D. no. 47 of on remuneration of employees of public law organizations in the field of science and innovation funded from the state budget; G.D. no of on approval of the Regulation on Norms of Expenses for Conduct of Conferences, Symposiums, Festivals, etc. by Public Institutions funded 6 from the State Budget; Order of the Minister of Finance no. 91 of Government Decision no. 731 of on approval of the Partnership Agreement between the Government and the Academy of Sciences of Moldova for the year NARE decisions on electricity tariffs. At the same time, the following useful documents will be taken into account 9 for information : Guide on completion of Technology Transfer projects; Guide on completion of the Business Plan; Guide of Resident of STP/II. 7 10

13 CHAPTER I GENERAL PROVISIONS 1.2 INSTITUTIONAL FRAMEWORK The Ministry of Economy and Infrastructure (MEI) is responsible for: Examination of applications to create IT parks; Submission of applications and related documents for approval to the Government; Conclusion of a contract for management of IT park with Administrator of the park; Examination of files submitted by residents of IT park to obtain opinion on invitation of qualified staff to implement certain projects for the benefit of resident. Monitoring of implementation of projects of residents; Development of policies to support residents. The Commission for examination and evaluation of requests of residents of the IT park for the opinion for the right of responsible residence for examination and evaluation of requests of residents of the IT park in order to issue the opinion necessary for granting the right of residence for the following categories of persons in the Republic of Moldova, as defined in the Law no. 200 of 16 July 2010 on Regime of Foreigners in the Republic of Moldova. 11

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15 CHAPTER II PROCEDURES FOR CREATION OF IT PARKS 2.1. REQUIREMENTS FOR SUBJECTS OF IT PARKS Requirements to be met by subjects of IT parks (applicants for creation of an IT park and residents of park). We distinguish two categories of active subjects of IT park: - Applicants for creation of a park; - Residents of park (after creation of the IT park, distinction between these two categories fades; not to mention applicants and residents, as all are qualified as residents with similar rights and obligations). Applicants for creation of an IT park are legal entities or individuals registered in the Republic of Moldova as subjects of entrepreneurial activity that have not/are not engaged in a process of insolvency or liquidation and/or restructuring as a result of insolvency or that entrepreneurial activity has not been/is not suspended, or that have not been/are not the subject of a legal procedure to be declared in one of these situations (Art. 5 of the Law no. 77/2016). The number of applicants for creation of an IT park is unlimited DOCUMENTATION FOR CREATION OF IT PARKS List and the content of documents to be submitted to the Ministry of Economy and Infrastructure. In order to create an IT park, applicants shall submit to the Ministry of Economy and Infrastructure an application for creation of a park with the goals of creation of the park, its functional orientation, as well as the activities to be carried out in the park (Art. 10 of the Law no. 77/2016). The following documents shall be attached to the application: a) copies of constituent documents of legal entity or individual requesting creation of the park; b) a feasibility study. The feasibility study on creation of the park shall include: 13 description of the concept of the park and the goals of its creation; argumentation of the possibility of carrying out the allowed activities and of attracting potential residents; the extent of staffing of potential residents of the park; stages and deadlines for creation of the park; amount of investments required to create the park and their sources.

16 2.3. PROCEDURES FOR CREATION OF IT PARKS Procedures to be followed for creation of IT parks and powers of the Ministry of Economy and Infrastructure The application for creation of an IT park shall be submitted by applicant to the Ministry of Economy and Infrastructure. The Ministry examines the application and the attached documents within 30 calendar days running from the date of submission of the application. If the Ministry finds that the submitted documents do not meet the requirements of the Law 77/2016, it may request the applicant to submit corrected documents and information. In this case, the 30calendar day period is extended by another 15 calendar days from the date of the additional request of the Ministry. If the applicant fails to submit corrected documents and information within the additional 25 calendar days or repeatedly submits documents that do not meet the requirements, the Ministry informs it, by a written notice, about the rejection of the application for creation of park and in all cases provides the reasons for such refusal. If after examination of the application a preventive decision for creation of park is made, the Ministry of Economy and Infrastructure shall submit to the Government for approval the draft decision to create an IT park, accompanied by the draft Regulation on Organization and Functioning of the Administration of the Park and the draft Regulation on Registration of Residents of the Park, and shall inform the applicant, with a written notice, about initiation of the procedure for creation of the park. The scheme of the procedure for creation of the park is given below: Applicant/s MEI 1 2 Submission of the application with attached documents Receipt of the documents by the MEI 3 4a 4b Examination of the request and the attached documents (30 days) Refusal 5 Preventive decision on creation 6 Presentation by the Government of the draft G.D. with the Regulation Approval of the GD 7 Signing of contract between the Administration and the MEI 14

17 CHAPTER II PROCEDURES FOR CREATION OF IT PARKS 2.4. PREVISIONS ON THE ADMINISTRATION. FORM OF ORGANIZATION OF THE IT PARK The Administration of the IT park is established by the Government based on a Government Decision. The Administration of the park is an administrative authority as defined in the Law no. 98 of on central specialized public administration. The Administration of the IT park has a legal personality and operates based on self-financing principles. By the Government Decision establishing the Administration of the IT park, the Regulation on Organization and Functioning of the Administration of the Park shall be approved. The Administration of the park is managed by an administrator, appointed by the Government as proposed by the Ministry of Economy and Infrastructure, for a period of 5 years. The administrator of the IT park and the Ministry of Economy and Infrastructure sign a contract on administration/management of the IT park defining the functions, rights and obligations of the administrator. The Law no. 77/2016 does not specify whether the administrator of the IT park shall be an individual or a legal person. Theoretically, the administrator of the park may also be a legal entity. In this case, it shall sign a (fiduciary) administration/management contract with the Ministry. The form of organization of the IT park is administrative authority established according to the Law no. 98 of on the central specialized public administration. 15

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19 CHAPTER III RESIDENTS OF IT PARKS. RESIDENT-ADMINISTRATOR RELATIONSHIP 3.1. WHO CAN BE RESIDENT OF IT PARK Resident of IT park may be any legal entity or individual registered in the Republic of Moldova as a subject of entrepreneurial activity that is included in the Register of Residents of the Park and that is engaged in one or several activities provided for in Art. 8 of the Law no. 77/2016, on the basis of a contract signed with the Administration of the Park (Art. 2 of the Law no. 77/2016). Residents of the IT park are registered under the procedures described in the Regulation on Registration of Residents of the Information Technology Park, approved by Government Decision. Residents of IT park carry out one or several activities described in Art. 8 of the Law no. 77. If a subject of IT entrepreneurial activity wishes to become resident of IT park, it must follow the steps below: Submission of an application to Administrator of IT park; Submission of documents related to its registration as subject of entrepreneurial activity; Signing a contract with Administration of the IT park. Applicants for creation of IT park are registered as residents ex officio. 17

20 3.2 RESIDENT-ADMINISTRATOR RELATIONSHIP Functions of the Administrator In accordance with the legislation in force, the duties of the Administrator include: Approval of the Regulation on Organization and Functioning of the Park, after consultation with the Ministry of Information Technology and Communications, and setting of objectives of the park; Management of the park in accordance with provisions of this law and other normative acts in force; Creation, maintaining and updating of the Register of Residents of the Park, as well as the official website of the park; Ensuring online access to the Register of Residents of the Park; Participation in evaluation of activity of the park, as appropriate; Contribution to attracting investors and inventors in the activity of the park; Submission of proposals to the Ministry of Information Technology and Communications on development of the activity of the park; Offing to residents of the park consulting services on the basis of a contract and their requests; Drawing up and submission to the Ministry of Information Technology and Communications of quarterly and annual reports on the activity of the park and its residents. The reports shall be made public on the official website of the park, and the data in these reports - on the single open data government portal; Representation of the park in relations with the central and local public administration authorities, if necessary; Development of the park projects. 18

21 CHAPTER III RESIDENTS OF IT PARKS. RESIDENT-ADMINISTRATOR RELATIONSHIP After registration of residents, the administrator shall also perform the following duties: Monitoring of residents, collecting their activity indicators; Organizing training and information sessions; Provision of specialized services; Initiation of withdrawal of the status of resident if it finds one of the grounds for withdrawal. By virtue of duties of the Administrator, the same shall sign with residents the following contracts: Service contracts; Contract for lease of premises in the park (if the IT park is physical); Machinery and equipment rental contract; Other types of contracts, as agreed between the administrator and the resident; Clauses of the contracts signed between the resident and the administrator shall be negotiated exclusively between them. The administrator can provide two main categories of services to residents: General services (rental, security, sewerage, Internet, telephony services, etc.) physical IT parks; Special services (financial-accounting audit, legal, marketing, consulting services, etc.). The nature and rates of the services provided, as per category, shall be set by the administrator taking into account the available infrastructure, specialization and team. The rates for rendered services shall be set in the service contract. The administrator is not entitled to oblige residents to use the services available. They are provided on request and as needed. 19

22 3.3 MONITORING OF ACTIVITY OF THE IT PARK Based on contracts between administrator and the MEI, annual activity Strategy and Plans, the administrator must monitor the activity of the IT park and present to the MEI the indicators achieved. The purpose of the monitoring is to assess constantly the activity of residents and the IT park by evaluating the activity indicators reached following implementation of technology transfer projects. Based on the monitoring, the Administrator prepares quarterly and annual reports and submits them to the MEI. The reports are made available on the official website of the park, and the data from these reports - on the single open data government portal. 3.4 WITHDRAWAL OF THE TITLE OF RESIDENT OF THE PARK In certain situations, provided by law, the title of resident is withdrawn by terminating the contract signed with the Administration of the park. These situations can be as follows: At the initiative of resident of the park, if the Administration of the park fails to observe the terms of the contract on activity in the park and fails not remove the violations within 3 months after receipt of the written notice from the resident; At the initiative of the Administration of the park, if the resident of the park fails to observe the terms of the contract on activity in the park and fails to remove the violations within 3 months after receipt of the written notice from the Administration; Violation of provisions of the present law, of the legislation on prevention and combating money laundering, other normative acts, on the basis of an final court decision in this respect; In other cases provided for by the contract on activity in the park.. In cases provided for in para. (1) let. a) and b), the title of resident of the park shall be withdrawn by decision of the Administration of the park. Withdrawal of the title of resident of the park entails deprivation of the resident of the incentives granted under this law. If residents whose title has been withdrawn do not agree with that decision, they may challenge it in court, in accordance with the rules of administrative litigation, by filing a prior claim to the administration of the park, and if it is rejected, they may submit it to a competent court. 20

23 IV CHAPTER BENEFITS OF THE STATUS OF RESIDENT 4.1 General Overview of the Tax Regime of Residents of IT Parks An important change in taxation of IT activities made for the first time in the Republic of Moldova as well as in the region, was made by the Law on Information Technology Parks no. 77 of (the framework law) and the Law amending and supplementing certain legislative acts no. 145 of , the latter aiming to adjust all legislative acts to the framework law. The novelty of the changes brought by the laws referred to above consists in benefiting from a distinct tax regime once the title of resident is obtained a regime aimed at facilitating IT activities. The peculiarity of the tax regime consists in application by residents of IT parks of the single tax in the amount of 7% of the sales income registered monthly in the accounting records. The amount of such income is determined in accordance with the National Accounting Standards or, as the case may be, the International Financial Reporting Standards. Other types of income (e.g. financial, exceptional income, etc.) are considered to be taxed by applying the single tax and are not taxed separately. Thus, the single tax includes, and therefore replaces 7 taxes and duties owed by residents of the park, and namely: The tax on income from entrepreneurial activity; the amount of this tax differs depending on of the legal form of organization, relevant to the IT activities being: Individual enterprise Annual taxable income* below 31,140 MDL Limited liability company Joint stock company Annual taxable income* Individual enterprise Annual taxable income* over 31,140 MDL Businesses of the sector of small and medium-sized enterprises 7% Income from operating activity 3% 12% 18% *The annual taxable income is the company's profit calculated by decreasing the income by the expenses incurred, with appropriate tax adjustments. 21

24 The tax on income from salary, which accounts for 7% for the taxable annual income below 31,140 MDL and 18% for the taxable annual income over 31,140 MDL; 1 The annual taxable income in this case is salary of employees, including rewards provided by employer, reduced by the sums of compulsory health insurance premiums and mandatory contributions to the state social security budget paid by individuals and personal exceptions of employee. It is worth mentioning that in case of employees of businesses, whose main activity is implementation of programs, the taxable income is the monthly income (established by the individual employment contract) whose amount does not exceed 2 average monthly salaries forecasted for the year concerned. Thus, the monthly income exceeding 2 average monthly salaries forecasted for the year concerned is treated as non-taxable income. Compulsory social security contributions due by employees and employers 2 EMPLOYEES 6% from the monthly salary and other rewards RATE EMPLOYER 23% from the payroll and other rewards, in case of employees of businesses whose main activity is implementation of programs - 2 average monthly salaries forecasted for the year concerned RATE Compulsory health insurance premiums due by employees and employers 3 EMPLOYEES 4,5% from the monthly salary and other rewards RATE EMPLOYER 4,5% from the payroll and other rewards RATE 22

25 CHAPTER IV BENEFITS OF THE STATUS OF RESIDENT Local taxes. 4 Currently, the Tax Code regulates 14 local taxes, the amount of which is set by local authorities, without any ceiling. We consider that the most relevant local duty for IT businesses is the land improvement duty payable for each employee. Its amount varies from one locality to another. Tax on real estate. 5 The rate of the real estate tax differs depending on the destination of the good; the good relevant to IT businesses is the real estate with commercial purpose, which makes up 0.3% of the estimated value of these goods. Duty for use of roads by motor vehicles registered in the Republic of Moldova. 6 The amount of the respective road duty is determined based on characteristics of motor vehicles (Appendix no. 1 Title IX of the Tax Code).. IMPORTANT: Once the title of resident of IT park has been granted, the company is no longer obliged to pay the aforementioned taxes. The other taxes and duties shall be paid by residents of IT parks in the generally established manner. Thus, the single tax does not include: The withholding tax, established in accordance with Art. 88 para. (5), Art. 89, 90, 901 and 91 of the Tax Code, State compulsory social security contributions and compulsory health insurance premiums calculated/withheld upon payments to the benefit of individuals, other than salary payments; Value added tax; Excises; Other road duties, except the tax for the use of roads by vehicles registered in the Republic of Moldova; Other taxes, duties and mandatory payments not expressly specified as part of the single tax. 23

26 The single tax is calculated on a monthly basis given the income recorded during the reporting month, without taking into account the cumulative data recorded since the beginning of the calendar year. If goods are returned or a discount is offered, the amount of the return of the goods or the discount will reduce the amount of the object of taxation in the tax period in which the goods were returned (the discount was granted), including if the related sales were reflected in the previous years. At the same time, the Law on Information Technology Parks and the Tax Code stipulate the minimum amount of the single tax to be paid by residents of IT parks, and namely 30% of the average monthly salary in the economy, forecasted for the year of the tax period of the tax concerned. The minimum single tax amount is calculated depending on the number of employees who worked during the tax period for at least one day on the basis of individual employment contract signed with the resident of the information technology park and the average monthly salary in the economy forecasted for the year to which the tax period concerned refers. The single tax is calculated and reported on a monthly basis. EXAMPLE: For a resident of IT parks with 20 employees, the amount of the minimum single tax to be paid in 2017 for each reporting month will make up 33,600 MDL (5,600 MDL * 30% * 20 employees). Thus, if the resident has a monthly sales income that multiplied by 7% tax rate will be less than the minimum amount of tax, it will pay that amount. EXAMPLE: In the case of the previous example. 1. For a sales income > 480 thousand MDL the amount of the tax will be the product between the sales income and the tax rate. 500,000*7%= 35,000 MDL Tax amount = 35,000 MDL 2. For sales income < 480 thousand MDL, the amount of the tax will be its minimum value. 460,000*7%= 32,200 MDL Tax amount = 33,600 MDL Residents of IT parks are not required to keep records of, and calculate, the wear and tear of fixed assets for tax purposes in the manner provided for in Title II of the Tax Code, which is made only for financial purposes in accordance with the established accounting norms. Upon pre-payment of dividends, residents of IT parks that apply the single tax will not be required to pay in advance the income tax in accordance with provisions of Art. 80 of the Tax Code. In case of the legal form of organization Limited Liability Company or Joint Stock Company, in case of distribution of dividends by residents of IT parks, they shall withheld a tax of 6% from the amount of dividends. Residents of parks with title of individual (individual entrepreneurs) will not include in the annual income tax return of individual for income derived from the activity carried out in the park. This regime is applied from the month immediately following the month in which the title of resident of IT park has been obtained, and ceases to apply from the month immediately following the month in which this title has been withdrawn. 24

27 CHAPTER IV BENEFITS OF THE STATUS OF RESIDENT At the same time, in order to maintain the title of resident of IT park, the obligation to carry out the main activities allowed in the IT park shall be fulfilled, by calculating the ratio between the amount of income obtained from sales of services, works allowed in the park according to Art. 8 of the Law on Information Technology Parks and the total amount of sales income included in the accounting records. In this case, both indicators related to the amount of sales income are calculated monthly, cumulatively from beginning of the respective calendar year or from beginning of the activity in the information technology park. Failure to reach the indicator related to the main activity during at most any 2 calendar months of the current calendar year is not considered a violation of the legal provisions, provided the indicator of 70% calculated as a total for the year concerned is reached Reporting and Payment of the Single Tax. Reporting of Other Information. The form and the manner of completing the report on the single tax are approved by the Order of the Minister of Finance no. 135 of 06 November The report is submitted to the subdivision of the State Tax Service at the location where the taxpayer provides services, until the 25th day of the month following the reporting month. A filled in template is given in Appendix no. 1. At the same time, according to Art. 374 of the Tax Code, besides the report on the single tax, residents of IT parks are required to submit the following information related to the single tax: To the State Tax Service: an information note on salary payments made by residents of information technology parks for the benefit of employees, until 25 January of the year following the calendar year in which payments were made for the benefit of employees, and has a fairly informative purpose; in particular for application of indirect taxation methods and sources. A filled in template is given in Appendix no. 2. To each employee: information on salary payments made by residents of information technology parks for the benefit of employees, including data on the number of months during which salary income paid was taxed by applying the single tax, until 1 March of the year following that in which such payments were made. A filled in template is given in Appendix no. 3. To the State Tax Service: report on income tax, withheld compulsory health insurance premiums and calculated state compulsory social security contributions. Residents of IT parks shall fill in only Table no. 2 and partially Table no. 3 (Appendix no. 4) in the part related to information on salaries calculated per each employee, as stated in point 4 of Appendix no. 2 to the Order of the Ministry of Finance on approval of the standard form (Form IPC18). The Report on withholding of income tax, compulsory health insurance premiums and calculated state compulsory social security contributions and the Instruction on filling in the nominated form no.126 of 4 October If residents of IT parks calculate payments for the benefit of third parties for services rendered, or works executed, other payments that make up the basis of calculation for the relevant contributions, they shall complete the Report (Form IPC18) in the generally established manner. 25

28 Similarly, according to Art. 5 (31) of the Law on the Public Social Security System no. 489-XIV of 8 July 1999, residents of IT parks are exempt from the obligation to submit a declaration on calculation and use of the state compulsory social security contributions. This exemption does not apply to social security contributions calculated for the income earned by employees and/or other individual on the basis of civil contracts concluded for execution of works or provision of services, which will be declared in a generally established manner. During 2018, in case of occurrence of the insured event (illness or affection) prior to the date of submission of the report on income tax, withheld compulsory health insurance premiums and calculated state compulsory social security contributions, residents of IT parks, as well as all other businesses, shall submit to the State Tax Service, through electronic reporting channels, or to the National Health Insurance Company, on paper, the information regarding the start of employment relationships, according to the list of nominal registration of employed insured persons (Appendix no.5). INFORMATION TO BE SUBMITTED BY RESIDENTS OF IT PARKS Nr. order Declarations / Regulatory act Single Tax RETURN (Appendix no. 1) Order of the Minister of Finance no. 135 of 06 November 2017 on approval of the forms of reports with respect to the single tax due by residents of information technology parks. INFORMATION NOTE on salary and other payments made by resident of IT park for the benefit of employees (Appendix no. 2) Order of the Minister of Finance no. 135 of 06 November 2017 on approval of the forms of reports with respect to the single tax due by residents of information technology parks. INFORMATION on salary and other payments made by resident of IT park for the benefit of employee (Appendix no. 3) Order of the Minister of Finance no. 135 of 06 November 2017 on approval of the forms of reports with respect to the single tax due by residents of information technology parks. Deadline for submission Monthly until the 25th day of the month following the reporting one Annually until 25 January of the year following the calendar year in which payments were made for the benefit of employees Annually, until 1 March of the year following that in which such payments were made REPORT Monthly, on withholding the income tax, compulsory health insurance premiums and until the 25th day calculated state compulsory social security contributions (Form IPC 2018) of the month following the (Appendix no. 4) reporting one Order of the Ministry of Finance no. 126 of 4 October 2017 on approval of the standard form (Form IPC18) The report on withholding of the income tax, the compulsory health insurance premiums and the calculated state compulsory social security contributions. and the Instruction on filling in the nominated form LIST of nominal registration of insured employees (Appendix no. 5) Order of the National Health Insurance Company no. 368 of on approval of forms of lists of nominal registration of persons insured in the compulsory heath insurance system Monthly, until the 7th day of the month following that in which changes took place 26

29 CHAPTER IV BENEFITS OF THE STATUS OF RESIDENT The single tax is to be fully paid to the state budget by the 25th day of the month following the reporting one, to the treasury account according to the IBAN code corresponding to their head offices. If resident of IT park has subdivisions outside the administrative-territorial unit in which the head office is located (legal address), the single tax is calculated and paid in full to the state budget according to the address of its head office (legal address). 4.3 Transition from Standard Tax Regime to Special Tax Regime In case of passage from the standard tax regime to the special one or vice versa, the new provisions apply from the month following the month in which the title of resident of IT park was obtained or the title was withdrawn accordingly. If salary payments due to employees are calculated during the period in which one of these (special or standard) tax regimes has been applied, and they are made in the period when the other tax regime applies, the income tax on salary, as well as the compulsory health insurance premiums related to these payments will be determined and paid on the due date of these salary payments, according to the mechanism applied at the date of their calculation. Also, residents of IT parks that during the tax year obtain the title of resident of IT park are not entitled to deduct for tax purposes the expenses related to the wear and tear and repair of fixed assets in the tax year concerned, which means that transition since 1 January is more advantageous. In the case of withdrawal of the title of resident of IT park for the period of application of the tax regime set out in this Title, expenses related to wear and tear and repair of fixed assets may be deducted according to the general norms. The input value of fixed assets per category of property for tax purposes is equal to the carrying value of these assets at the beginning of the month following the month in which the title of resident of IT park has been withdrawn. If in the course of the tax year the taxpayer applies both the standard tax regime and the special tax regime, the taxable income is determined as the difference between the amount of gross income obtained during the period of application of the tax regime set out in Title II of the Tax Code and the amount of expenses that may be deducted according to the Title concerned, taking into account the particularities listed above. With the passage from the special tax regime to the standard one, the losses incurred by residents of IT parks in the period of application of the special regime cannot be taken into account in determining the amount of losses to be reported in accordance with provisions of Art. 32 of the Tax Code. 27

30 4.4 CONSEQUENCES OF NON-COMPLIANCE WITH THE SPECIAL TAX REGIME If the State Tax Service finds that resident of IT park has breached the conditions of the special tax regime to be met so as to apply the single tax, the tax obligations of the resident concerned, as well as its obligations related to payment of compulsory social security contributions and compulsory health insurance premiums will be recalculated in the general manner established from the month in which the violation was committed. Payments resulting from recalculation of taxes, contributions and other payments are made out from source of resident of the IT park without recalculating the obligations of its employees. Residents of IT parks shall be responsible for breaches of conditions of the special tax regime to be met so as to apply the single tax, according to Title V of the Tax Code, except for in delay increase (penalty). Residents of IT parks that missed the due date of the single tax shall pay the (calculated) delay increase in the amount established in the annual law of the state social security budget, which for 2017 makes up 0.1% of the debt for each day of delay, including for the day of transfer of the amount due. The delay increase is paid to the same treasury account of receipts as the single tax and is distributed pro rata as per different components of the national public budget. The applied and calculated fines are not part of the single tax and shall be paid, in the generally established manner, to the treasury account of receipts, other than the single tax, according to the separate economic classification. 4.5 FEATURES OF TAXATION OF EMPLOYEES OF RESIDENTS OF IT PARKS Salary payments received by employees of residents of IT parks are considered as finally taxed. The employer (resident of IT park) shall not calculate and withhold the state compulsory social security contributions, compulsory health insurance premiums and income tax related to salary income paid, and employees shall not be required to declare the income concerned, as well as to pay additionally the income tax. Other income of employees (excluding salary) and payments made for the benefit of other individuals shall be taxed under general principles. Thus, for the period of application of the single tax, residents of IT parks are not obliged to fill in the personal record sheet of salary income and other payments made by resident for the benefit of its employees. Also, for the period of application of the single tax, employees of IT parks cannot benefit from personal exemptions, exemptions granted to spouses or exemptions for dependents, as well as other exemptions and other deductions related to salary payments made by residents of IT parks. Unused exemptions in this case cannot be transferred to spouse. This rule is also valid in cases when in the course of a year individuals have earned both income subject to the single tax and other types of income (including salaries). Exemptions granted to employee of resident of IT park for the period of the standard regime are not applied from the month following the month in which the employer has obtained the title of resident of IT park. 28

31 CHAPTER IV BENEFITS OF THE STATUS OF RESIDENT Employees of residents of IT parks benefit from all types of state social security benefits from the state social security budget (allowance for temporary incapacity for work caused by ordinary disease or work-related accidents, maternity allowance, sick child care allowance, etc.). The monthly insured income of these employees will be 60% of the average monthly salary in the economy, forecasted for the year concerned, regardless the actual amount of salary received for the work performed in the park, the number of days worked during the month and his/her work schedule (full time or part time). If the employee worked during the month both within and outside an IT park, the insured monthly income consists of the income from which individual social security contributions have been calculated and 60% of the monthly average salary in the economy, forecasted for the year concerned, except for cases of calculation of the paternal allowance, which is made based on the average monthly insured income obtained at the basic job). Likewise, employees of residents of IT parks obtain the status of insured person in the compulsory health insurance system based on lists of nominal registration of insured employees, submitted and updated by residents of the park BENEFITS OF THE TAX REGIME APPLICABLE TO RESIDENTS OF IT PARKS The basic objective underlying development and adoption of the Law on Information Technology Parks no. 77 of is stimulation of development of the IT industry, including boosting competitiveness on the regional and international market by creating conditions facilitating activity of local IT companies. Moreover, this concept aims to provide an environment conducive to development of innovative IT businesses, attracting foreign investments and qualified IT specialists in order to develop and implement competitive IT products and services. The benefits of the tax regime for residents of IT parks consist mainly of reduced tax burden; simplicity. Data of the analysis of the template of single tax and import incentives for residents of IT parks show an effective tax rate (the amount of taxes included in the single tax in relation to income derived from sales) amounting to 12.7%. It is worth mentioning that during the last 5 years there have been no significant changes in the tax structure to be included in the single tax, which is why we conclude that the effective tax rate remained within the value of 12.7%. As the single tax rate is 7% of the sales income, we find out that residents of IT parks will benefit from a reduction of the tax burden of about 5.7% in relation to the sales income, ensuring a competitive advantage on the regional and international market of IT products. 29

32 INDICATORS, Income tax on entrepreneurial activity 16,790,016 Lei Income tax on salary 41,476,804 Lei Social security contributions (due by employers and employees) 120,387,612 Lei Health insurance premiums (due by employers and employees) 29,100,846 Lei Local duties 741,694 Lei Tax on real estate 404,908 Lei Road duties 171,801 Lei Total amount of taxes and duties declared in ,073,681 Lei Total sales income in ,649,760,891 Lei Effective tax rate in 2012 (in relation to the sales income) 12.7% SOURCE: Analysis of the template of the single tax and import incentives for residents of IT parks. Simplicity of the tax regime is due to lack of calculation, reporting and payment of taxes included in the single tax (7 taxes and payments), as well as the lack of the obligation to keep records of, and to calculate, the wear and tear of fixed assets for tax purposes, as provided for in Title II of the Tax Code, which are performed only for financial purposes in accordance with the established accounting rules. It is worth mentioning that the simple tax regime has the following advantages: Reduced time and staff needed for tax calculation and accounting; Significantly reduced risk of committing errors in calculating the tax obligations; Significantly reduced risk of sanctioning by inspection authorities. 30

33 CHAPTER IV BENEFITS OF THE STATUS OF RESIDENT Residents of IT parks also benefit from guarantees related to application of the single tax. Thus, if new laws are adopted to change the rate and/or composition of the single tax levied on residents of IT parks and/or to cancel it, residents of the park are entitled, during a period of 5 years from the date of entry into force of the Law on Information Technology Parks no. 77 of (until 2021), which, however, shall not exceed the operational period of the respective park, to operate according to the laws in force until the date of entry into force of the new laws. If certain taxes and/or duties included in the single tax levied on residents of IT parks are replaced by other taxes and/or duties, the composition of the single tax will be adjusted accordingly, without changing its rate. Besides the benefits of applying the single tax, residents of IT park are given the following incentives: Financial allocations, obtained through competition within state programmes; Possibility to benefit from financial means from risk funds, created with involvement of the Government; Other tax and customs incentives provided for by tax and customs legislation. Other tax and customs incentives provided for by tax and customs legislation are tax incentives granted in case of taxes and duties other than those included in the single tax, in case of residents of IT parks, while the value added tax is relevant. The main VAT-related incentives that residents of IT parks can benefit from are: Exemption from VAT of long-term tangible assets directly used in manufacture of products, upon provision of services and/or execution of works, intended to be included in statutory (authorized) capital;) Repayment of VAT in case of capital investments (expenditures). Capital investments (expenditures) means expenditures incurred by businesses in connection with purchase and/or creation of long-term assets to be used in production (performance of services/execution of works), which are not reflected in the profits and losses of the current period, but are to be included in increase in the value of long-term assets. Thus, residents of IT parks can benefit from the incentives referred to above in acquiring/buying or importing long-term assets, for example, computing equipment. 31

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35 CHAPTER V TERMINATION OF ACTIVITY OF IT PARK An IT park may be wound-up only by a Government Decision as proposed by the MEI, in the following cases: The park does not achieve the objectives stipulated by this law and its own regulation on organization and functioning. The Government Decision on winding-up of the park comes into force 6 months after its publication; Expiration of the term for which it has been established and after expiration of this term the decision to extend the term of activity of the park is not approved. Winding-up of the park entails loss of the title of resident of the park and termination of the regime of incentives granted to residents of park under the present law. 33

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37 APPENDIXES to the Order of the Ministry of Finance no. APPENDIX of 06 November 2017 Form IU 17 Single Tax Return Name of taxpayer IT PARC LLC Tax code Code of settlement (CATUM) Name of subdivision of the STS BOTANICA SECTOR Main type of activity according to the CEAM customized software development activity (customer oriented software) Registration code of resident of the park Indicators 1 Total sales income/ Number of employees during the tax period, employed on the basis of employment contracts Amount of single tax due (indicate the maximum amount between code 010 and code 020 col.6) Tax period L/12/2017 Date of submission 15/ Code Taxable base (amount, number of employees) Amount of the average monthly salary in the economy, forecasted for the reporting year Share of the single tax Amount of the single tax, (MDL) ,000 x 7% 35, , x x 30% x 33,600 35,000 Hash total 35,000 (amount row 030, col.6) We declare that the information in the report is true and we are liable according to the legislation in force, if false or uncertain information is included. Head/ 35 (signature) Chief Accountant/ (signature)

38 Continuation APPENDIX 1 Appendix to the Single Tax Return Indicators related to determination of the share of activity carried out in the park by residents of the park, according to Art. 8 of the Law on Information Technology Parks Cr. No. 1 Indicators Monthly, reported tax period From the beginning of the calendar period Sales income from the Return (code 010 col. 3), including: 500,000 5,000,000 2 Income from sales of services, works allowed in the park according to Art. 8 of the Law on Information Technology Parks 450,000 4,000,000 3 Share of activity performed in the park (%) (row 2 : row 1 x 100) 90% 80% 36

39 APPENDIXES APPENDIX 2 Appendix no. 3 to the Order of the Ministry of Finance no. 135 of 06 November 2017 Form ISAPTI 17 INFORMATION NOTE on salary and other payments made by the resident of the information technology park for the benefit of employees Name of subdivision of the STS 03 - BOTANICA SECTOR Calendar year 2017 Main type of activity according to the CEAM customized software development activity (customer oriented software) Date of submission Registration code of resident of the park Number of entries 20 Code of settlement (CATUM) 0100 Name of taxpayer Tax code Cr. No. IT PARC LLC Tax code of employee Name and surname of employee Turcan Eduard 1 1. Amount of income from salary, incentive payments and compensation, (MDL) No. of months in which the employee worked in the information technology park 4 240, ,800,000 X Etc. Total Hash total 4,800,000 (total amount per Note, col.4) The current number shall be specified consecutively throughout the Note, regardless of the number of pages. Head Chief Accountant 37

40 APPENDIX 3 Appendix no. 5 to the Order of the Ministry of Finance no. 135 of 06 November 2017 INFORMATION on salary and other payments made by the resident of information technology park for the benefit of employee no. 15 of 20 February 2017 Hereby 'IT PARC LLC, (name of the resident of the IT park, tax code) confirms that Turcan Eduard, (name, surname and tax code of the employee for whose benefit payments were made) during the year 20 benefited from the following income for the activity carried out in the information technology park: Amount of income in the form of salary, incentive payments and compensation (MDL) 1 240,000 No. of months in which the employee worked in the information technology park 2 12 Note: The person obliged to submit this information shall keep a confirmation that this information has been provided or served to the person for whose benefit the payments had been made. Head (signature) Chief Accountant (signature) 38

41 APPENDIXES APPENDIX 4 Appendix no. 1 to the Order of Ministry of Finance no. 126 of 4 October 2017 Form IPC18 REPORT on withholding of income tax, compulsory health insurance premiums and calculated state compulsory social security contributions Name of State Tax Service taxpayer Resident of IT parks Code of the main activity according to the CEAM Tax code Code of settlement (CATUM) Type of report (tick) NSIC code primary report correction report After tax inspection Date of submission Tax period APPENDIX 4 Table no. 1 Amount of paid income, income tax and compulsory health insurance premiums withheld from it / (not to be necessarily filled in for employees of residents of IT parks) Table no. 2 Information on commencement, suspension and termination of employment relationships / No Name, State surname of identification the number of the individual individual 2 3 Personal social security code (PSSC) 4 Code of function granting the right to retirement in special conditions 5 Date, Code of changes Date of month of employment assignment to and relationships the category year of (status of specified in birth insured person) col.5 / col

42 Continuation APPENDIX 4 Appendix to the Single Tax Return 40

43 APPENDIXES APPENDIX 3 Appendix no. 3 to the Order of Ministry of Finance no. 126 of 4 October 2017 Form DSA18 I N FO R M AT I O N on establishment of social rights in the social security system Name of taxpayer Tax code State Tax Service Cr. No. /no. of mont h Name, surna me of insure d person Identifica tion number of insured person (IDNP) Personal social security code (PSSC) Period of work and temporary incapacity for work Reporting month, year NSIC code from till 5 6 Date of submission Category of insured person Code of function Payroll fund and other rewards Allowance for temporary incapacity for work Calcul ated individ ual social securit y contri bution Calculated contributio ns due by employer Head Accountant Chief (FORM DSA18 shall be submitted by employers only if the reported information contains no financial data and reflects only the period in which a person is at insured risk (on leave to care for a child up to the age of 3, on paternity leave), and the relevant category of the Classifier of the categories of insured persons. This form is to be filled strictly if it is necessary to reflect the mentioned situations by indicating the information in accordance with the orders prepared by the employer, which will form the basis for establishing the social security benefits. The declared information shall be submitted during the reporting month and shall be intended to declare the status of insured person to whom, in case of occurrence of the insured risk, it is necessary to establish the right to benefit). 41

44 APPENDIX 5 Appendix no. 1 to the Order of the National Health Insurance Company no. 368-A of Form no. 2-03/l LIST of nominal registration of insured employees la name of employer - unit IDNO/Tax Code Or. No. State Identity Number of Individual (IDNP) or series and provisional ID number 1 2 Name, surname and patronymic of the person Date, month, year of birth Status of the person (1 employee, 2 - dismissed, 3 suspended IEC, 4 - cancellation of IEC suspension. Date of assignment to the category indicated in column The insured person employed / dismissed / suspended the IEC on /cancelled suspension of the IEC for persons. Date of submission 20 INSURED PERSON Stamp here INSURER National Health Insurance Company Territorial Agency 42

45 Photo Credit: Proiectul de Competitivitate Photo Credit: Proiectul de Competitivitate Photo Credit: Proiectul de Competitivitate Photo Credit: Proiectul de Competitivitate