ISD will no longer qualify as tax credit.
SRF LAW FIRM informs that, in accordance with Ruling No. 58-11-IN/22 and Verification Order No. 58-11-IN/23 issued by the Constitutional Court, the Foreign Currency Exit Tax (ISD) will no longer be usable as a tax credit starting from 1 January 2025.
The Law on Environmental Promotion and Optimisation of State Revenues, which regulated the use of ISD as a tax credit, was declared unconstitutional due to procedural violations, specifically for contravening the principle of legislative unity.
Implications for taxpayers:
From 1 January 2025, the ISD can no longer be treated as a tax credit but only as an expense. Companies must adjust their tax planning strategies in accordance with this regulatory change.
