Casablanca GMT
Ernst & Young Morocco
+212 (522) 957-900 37, Bd Abdellatif Ben Kaddour Fax: +212 (522) 390-226 Casablanca Morocco Business Tax Services
Abdelmejid Faiz +212 (522) 957-900 Email: abdelmejid.faiz@ma.ey.com
Business Tax Advisory and Tax Policy and Controversy
Abdelmejid Faiz +212 (522) 957-900 Email: abdelmejid.faiz@ma.ey.com
Kamal Himmich +212 (522) 957-900 Email: kamal.himmich@ma.ey.com
A. At a glance
Corporate Income Tax Rate (%) 31 (a)
Capital Gains Tax Rate (%) 31 (a)(b)
Branch Tax Rate (%) 31 (a)
Withholding Tax (%)
Dividends 15 (c)
Interest 10/20/30 (d)
Royalties, Scientific Know-how Payments, Technical Assistance Fees and Remuneration for Most Services 10 (e)
Wages and Indemnities Paid to Non-permanent Employees 30 (f) Rent on Equipment Used in Morocco 10 (e) Branch Remittance Tax 15 (b)
Net Operating Losses (Years)
Carryback 0
Carryforward 4 (g)
(a) Corporate income tax is imposed at proportional rates ranging from 10% to 31% (for details, see Section B). The corporate income tax rate is 37% for banks, financial institutions and insurance companies. Corporate income tax incentives are available (see Section B).
(b) See Section B.
(c) The dividend withholding tax is a final tax for nonresidents. Withholding tax does not apply to dividends paid to Moroccan companies subject to Moroccan corporate tax if a property attestation (a certificate containing the company’s tax number and attesting that the company is the owner of the shares) is delivered by the beneficiary company. Withholding tax does not apply to dividends paid by companies benefiting from Casablanca Finance City (CFC) status. This exemption is subject to certain conditions for companies that obtained CFC status before 2020.
(d) The 10% rate applies to interest paid to nonresidents on loans or other fixedinterest claims. The 10% tax is a final tax. The 20% rate applies to interest paid to resident companies and interest paid to resident self-employed indi viduals in connection with a business conducted by the recipient. The 20% tax may be credited by recipients against their total income tax. The 30% rate applies to interest payments made to resident individuals if the payments are unrelated to a business conducted by the recipient. The 30% tax is a final withholding tax.
(e) This is a final tax applicable only to nonresidents. Rental and maintenance of aircraft used for international transport are exempt from this withholding tax.
(f) This withholding tax applies only to payments to persons who are not salaried employees and do not hold a special function in the company paying the indemnities. The rate is 17% for teachers. (g) Losses attributable to depreciation may be carried forward indefinitely.
B. Taxes on corporate income and gains
Corporate income tax. The following companies are subject to corporate income tax:
• Resident companies (those incorporated in Morocco)
• Nonresident companies deriving taxable income from activities carried out in Morocco
• Nonresident companies deriving capital gains from sales of unlisted shares and bonds in Morocco (unless a double tax treaty between Morocco and the residence country of the ben eficiary provides otherwise)
• Branches of foreign companies carrying on business activities independent of those performed by their head office
In general, only Moroccan-source income is subject to tax unless a provision of a double tax treaty provides otherwise.
Tax rates. The proportional tax rates in the following scale apply for corporate income tax returns submitted for financial years beginning on or after 1 January 2022.
Taxable income Exceeding Not exceeding Rate MAD MAD % 0 300,000 10 300,000 1,000,000 20 1,000,000 5,000,000 31*
* The marginal rate of 31% is reduced to 26% for companies carrying out indus trial activities with a net profit of less than MAD100 million.
Banks, financial institutions and insurance companies are subject to tax at a rate of 37%.
The minimum tax equals the greater of the minimum fixed amount of MAD3,000 and 0.5% of the total of the following items:
• Turnover from sales of delivered goods and services rendered
• Other exploitation income (for example, directors’ fees received when the company acts as an administrator of another company, revenues from buildings that are not used in the company’s activities, and profits and transfers of losses with respect to shared operations)
• Financial income (excluding a financial reversal and a transfer of financial expenses; a financial reversal refers to an accounting record reflecting the decrease or cancellation of the financial provision [generally related to foreign-exchange risk] already recorded in the previous fiscal year, while a transfer of financial expenses refers to an accounting record to allocate expenses over multiple years)
• Subsidies received from the state and third parties
The rate of minimum tax is reduced to 0.25% for sales of petroleum goods, gasoline, butter, oil, sugar, flour, water, electricity and medicine. The minimum tax applies if it exceeds the corpo rate income tax resulting from the application of the proportional
rates or if the company incurs a loss. New companies are exempt from minimum tax for 36 months after the commencement of business activities.
If a company declares a negative operating income, excluding depreciation, for two consecutive fiscal years and is beyond the 36-month exemption period, the minimum tax rate is increased to 0.6%. However, if the current result excluding depreciation is declared positive, the minimum tax rate is decreased to 0.4%.
Nonresident contractors may elect an optional method of taxation for construction or assembly work or for work on industrial or technical installations. Under the optional method, an 8% tax is applied to the total contract price including the cost of materials, but excluding VAT.
Social Solidarity Contribution. Under the 2022 Finance Law, the Social Solidarity Contribution (SSC) is imposed on the profits and income in 2022 of companies subject to corporate income tax, as defined by Article 2-III of the Moroccan Tax Code, excluding the following:
• Companies that are permanently exempt from corporate income tax
• Companies operating in industrial acceleration zones (former free trade zones)
• Companies operating under the CFC tax regime
For companies subject to the SSC, this contribution is calculated on the basis of the taxable income on which corporate income tax is computed, equal to or greater than MAD1 million for the latest closed financial year. The following are the rates of the SSC:
• 1.5% for companies with taxable income ranging from MAD1 million to MAD5 million
• 2.5% for companies with taxable income ranging from MAD5 million to MAD10 million
• 3.5% for companies with taxable income ranging from MAD10 million to MAD40 million
• 5% for companies with taxable income exceeding MAD40 mil lion
Tax incentives. Morocco offers the same tax incentives to domestic and foreign investors. Various types of companies benefit from tax exemptions and tax reductions, which are summarized below.
Permanent exemptions. Permanent tax exemptions are available to agricultural enterprises and cooperatives with annual turnover of less than MAD5 million, excluding VAT.
Capital risk companies are exempt from corporate income tax on profits derived within the scope of their activities (these are prof its related to purchases of companies’ shares that support such companies’ development and the sales of such shares thereafter).
Total exemption followed by permanent reduction. Hotel companies benefit from a tax exemption and a tax reduction with respect to their profits corresponding to their foreign currency revenues that are generated by their hotels and are remitted to Morocco either directly or through travel agencies. Hotel compa nies are fully exempt from tax on such profits for the first five
years following their first foreign currency sale operation, and they benefit from a maximum proportional tax rate of 20% on such profits in subsequent years. Management companies of “real estate residences for tourism promotion” also benefit from this measure, under the same conditions. A “real estate residence for tourism promotion” is a residence assimilated to a hotel in which the housing units belong to one or more owners and of which a minimum percentage of the housing units (fixed by regulations at 70%) is managed by a licensed management company for at least nine years.
Companies that obtained Casablanca Finance City (CFC) sta tus as of 1 January 2020 benefit from a total corporate income tax exemption for a period of five consecutive fiscal years from the first fiscal year of obtaining their CFC status. Subsequently, a reduced flat rate of 15% applies. The 2021 Finance Law excludes from the benefit of such tax advantages the following companies:
• Credit institutions
• Insurance and reinsurance companies
• Insurance and reinsurance brokerage companies
Transitional regimes apply to companies that obtained CFC sta tus before 1 January 2020. The tax regime that was in force before 1 January 2020, providing for the application of a reduced corporate income tax rate of 8.75% on income from export turnover and the taxation of income from local turnover at the stan dard corporate income tax rates, remains applicable until 2022 for service companies that obtained their CFC status before 1 January 2020.
Export companies that establish in Moroccan industrial accelera tion zones (formerly called free zones [zones franches]) as of 1 January 2021 will benefit from a total corporate income tax exemption for five consecutive fiscal years. Subsequently, a re duced flat rate of 15% applies. Transitional measures apply to companies already established in such zones, which will be set up before 1 January 2021.
From the 2020 fiscal year, companies carrying out service out sourcing activities within or outside the integrated industrial platforms benefit from a total corporate income tax exemption for the first five years of their activity. Subsequently, a maximum proportional tax rate of 20% applies.
Sports companies benefit from a total corporate income tax ex emption for the first five years of their activity. Subsequently, a maximum proportional tax rate of 20% applies.
Permanent reductions. Mining companies, including those that sell products to export companies, benefit from a maximum pro portional corporate income tax rate of 20%. As of 1 January 2020, export companies are taxed up to a maximum proportional tax rate of 20%. Exporters of recycled metals cannot benefit from the 20% rate.
Under a transitional measure, export companies that carried out their first export transaction before 1 January 2020 are exempt from corporate income tax on their income relating to export
turnover during the first five years following their first export transaction.
For exports of services, the 20% rate applies if both of the follow ing conditions are met:
• The related turnover must be realized in foreign currencies (other than dirhams) that is properly repatriated to Morocco.
• The currencies must be repatriated to the Moroccan bank account of the company.
Agricultural companies that become taxable (turnover exceeds MAD5 million) are taxed up to a maximum proportional tax rate of 20%.
Temporary exemption. Companies holding a hydrocarbon exploration and exploitation permit are exempt from corporate income tax for 10 years from the beginning of hydrocarbon regular pro duction.
Subject to certain conditions, real estate developers benefit from a total exemption from corporate income tax and other taxes with respect to construction programs for social housing under agreements entered into with the government. This temporary regime applies from 1 January 2010 through 31 December 2020.
Temporary reduction. Handicraft companies, private schools and educational institutes benefit from a maximum proportional cor porate income tax rate of 20% for their first five years of opera tions.
Tax-free intragroup restructuring. The 2017 Finance Law introduced a new provision establishing a tax-neutrality mechanism for the sale of fixed assets between companies of the same group. This regime allows the transfer or sale of these assets without affecting the taxable income of the transferor. It applies if the concerned companies are part of a group created by a parent company and includes only companies in which it holds directly or indirectly at least 80% of the share capital. At the transferee level, depreciation on fixed assets is tax deductible, but such deduction is limited. These transactions are subject to a fixed registration duty of MAD1,000.
The 2020 Finance Law provides for the extension of this regime to transfers of intangible and financial assets.
Exemption for newly incorporated industrial companies. To pro mote investment in the industrial sector, the 2017 Finance Law provides for an exemption from corporate income tax for newly created industrial companies for a period of five consecutive years from the starting date of business operations. The eligible industrial activities for this tax incentive will be defined by de cree.
Capital gains. Capital gains on the sale of fixed assets are taxed at the proportional corporate income tax rates (see Tax rates).
Nonresident companies are taxed on profits derived from sales of unlisted shares of Moroccan companies at the proportional corpo rate income tax rates, unless a double tax treaty between Morocco and the residence country of the beneficiary provides otherwise.
In addition, they must file an income declaration before the end of the month following the month in which the sales occurred.
Companies will temporarily benefit from a reduction of 70% on the net capital gain arising from the disposal of fixed assets, excluding land and buildings. This measure applies only for fiscal years beginning in 2022.
The 2022 Finance Law provided the following conditions for the application of this measure:
• Eight-year holding period for the disposed assets
• Commitment to reinvest the total disposal amount within 36 months
• Obligation to maintain the new assets for at least five years
• Reporting to the tax administration
Special rules apply to mergers and liquidations of companies (see Section E).
Administration. Within three months after the end of their financial year, companies must file a corporate income tax return with the local tax administration where their headquarters are located. The companies’ financial statements must be enclosed with the return.
Companies must make advance payments of corporate income tax. For companies with a 31 December year-end, the payments must be made by 31 March, 30 June, 30 September and 31 December. Each payment must be equal to 25% of the previous year’s tax.
Companies must report the SSC within three months after the clos ing date of the preceding financial year. In addition, they must pay SSC due at the same time as the reporting.
If the minimum tax does not exceed MAD3,000, it is fully payable in one installment. Payment of the minimum tax exceeding this amount is made in accordance with the rules applicable to the corporate income tax.
Dividends. Dividends are generally subject to a 15% withholding tax. However, withholding tax does not apply to dividends paid to Moroccan companies subject to Moroccan corporate tax if a property attestation is delivered by the beneficiary company. Such companies are also exempt from corporate income tax on the dividends.
Foreign tax relief. Foreign tax relief is granted in accordance with the provisions of Morocco’s double tax treaties and the Moroccan Tax Code.
C. Determination of trading income
General. The computation of taxable income is based on financial statements prepared according to generally accepted accounting principles, subject to modifications provided in the Moroccan Tax Code.
Business expenses are generally deductible unless specifically excluded by law. The following expenses are not deductible:
• Interest paid on shareholders’ loans in excess of the interest rate determined annually by the Ministry of Finance or on the por tion of a shareholder’s loan exceeding the amount of capital
stock that is fully paid up. No interest on shareholders’ loans is deductible if the capital stock is not fully paid up.
• Certain specified charges, gifts, subsidies, corporate income tax and penalties.
Inventories. Inventory is normally valued at the lower of cost or market value.
Provisions. Provisions included in the financial statements are generally deductible for tax purposes if they are established for clearly specified losses or expenses that are probably going to occur.
Provisions on bad debts are deductible if a court action is insti tuted against the debtor within 12 months after the booking of the provision.
Depreciation. Land may be amortized only if it contributes to production (for example, mining lands). Other fixed assets may be depreciated using the following two methods:
• The straight-line method at rates generally used in the sector of the activity.
• A declining-balance method with depreciation computed on the residual value by applying a declining coefficient that ranges from 1.5 to 3 and that is linked to the term of use. The decliningbalance method may not be used for cars and buildings.
The following are some of the annual applicable straight-line rates.
Asset Rate (%)
Commercial and industrial buildings 4 or 5 Office equipment 10 to 15 Motor vehicles (for vehicles used in tourism, the maximum depreciable value is MAD300,000 including VAT) 20 to 25 Plant and machinery 10 to 15
Certain intangible assets, such as goodwill, do not depreciate over time or by use and, consequently, are not amortizable.
Relief for tax losses. Losses may be carried forward for four years; losses attributable to depreciation may be carried forward indefi nitely. Losses may not be carried back.
Groups of companies. Moroccan law does not provide taxconsolidation rules for Moroccan companies.
D. Other significant taxes
The following table summarizes other significant taxes.
Nature of tax Rate (%)
Value-added tax, on goods sold and services rendered in Morocco
General rate 20 Electric power, transport of tourists and certain other items 14
Restaurants, hotels, cooking salt, bank operations and certain other items 10 Utilities (water provided through public distribution network and oil), pharmaceuticals, sugar, preserved sardines and dried milk
Nature of tax Rate (%)
Professional tax, on gross rental value of the business premises 10 to 30 Communal services tax (tax base similar to professional tax) 6.5/10.5
Registration duties, on transfers of real property or businesses 1 to 6
Professional training tax, on gross salaries including fringe benefits 1.6
Social security contributions, paid by employer For family allowances, on gross monthly remuneration (no maximum limit of remuneration applies) 6.4
For illness and pregnancy, on gross monthly remuneration, up to a maximum remuneration of MAD6,000 a month 8.6 For required medical care 3.5
E. Miscellaneous matters
Foreign-exchange controls. Remittances of capital and related income to nonresidents are guaranteed. No limitations are im posed on the time or amount of profit remittances. The remit tance of net profits on liquidation, up to the amount of capital contributions, is guaranteed through transfers of convertible cur rency to the Bank of Morocco.
As a result of the liberalization of foreign-exchange controls, foreign loans generally do not require an authorization from the exchange authorities. However, to obtain a guarantee for the remit tance of principal and interest, notes are commonly filed at the exchange office, either through the bank or directly by the borrower. In general, if the loan’s conditions are equivalent to those prevailing in foreign markets, the exchange office approves the loan agreement. The loan agreement must be filed with the exchange office as soon as it is established.
To promote exporting, Moroccan law allows exporters of goods or services to hold convertible dirhams amounting to 50% of repatriated currency. Exporters must spend these convertible dirhams on professional expenses incurred abroad. Such expens es must be paid through bank accounts of convertible dirhams, called “Convertible Accounts for the Promotion of Export” (Comptes Convertibles de Promotion des Exportations).
Transfer pricing. The 2019 Finance Law introduced the require ment of electronic communication to the tax authorities of the pricing documentation to support a company’s price policy, nota bly in the case of a tax audit.
Such documentation should include the following:
• Information relating to activities with the group entities, the global pricing policy practiced and the breakdown of the world wide profit and activities
• Specific information relating to the transactions performed by the Moroccan entities with group entities
The above provisions apply to tax audits opened from 1 January 2020. Practical procedures for these provisions are to be detailed in a decree still to be published.
The 2021 Finance Law introduces the obligation to provide transfer-pricing documentation in the event of a tax audit for companies that have carried out cross-border intragroup transac tions, in order to justify their transfer-pricing policy. The Finance Law provides that this documentation must include the follow ing:
• A Master File containing information on all activities of affili ated entities, the overall transfer-pricing policy applied and the distribution of profits and activities worldwide
• A Local File containing specific information on the transac tions that the audited company carries out with other companies with dependency links
This obligation applies to the companies meeting either of the following conditions:
• Turnover equal to or greater than MAD50 million
• Gross assets of MAD50 million or more
The 2021 Finance Law introduces a sanction for a failure to produce transfer-pricing documentation, calculated at a rate of 0.5% on the amount of transactions related to the non-produced docu ments with a minimum of MAD200,000.
The details of application of the transfer pricing documentation provisions will be determined by decree, which had not yet been issued at the time of writing.
Country-by-Country reporting. The 2020 Finance Law introduced an obligation to report the worldwide distributions of profits of multinational groups of companies (Country-by-Country [CBC] reporting) and a sanction for failure to produce such report.
CBC reporting is a country-by-country breakdown of tax and accounting data and information on the identity, place of opera tion and nature of activities relating to multinational groups to which Moroccan companies belong.
This measure applies to companies that meet the following crite ria:
• They hold, directly or indirectly, an interest in one or more companies or establishments located outside Morocco, which requires them to prepare consolidated financial statements in accordance with applicable accounting standards or they would be required to do so if their shares were listed on the Moroccan stock exchange.
• They achieve an annual consolidated turnover, excluding taxes, higher than or equal to MAD8,122,500,000 for the fiscal year preceding the one concerned by the report.
• They are not owned directly or indirectly, as described in the first bullet above, by any other company located in or outside Morocco.
This obligation also applies to any company that fulfills one of the following conditions:
• It is directly or indirectly owned by a company located in a country that does not require the filing of CBC Reports (CBCRs) and which would be required (that is, the parent com pany) to file such reports if it were located in Morocco.
• It is owned directly or indirectly by a company located in a country with which Morocco has not concluded an agreement
containing provisions on exchange of information for tax pur poses.
• It has been appointed for such purposes by the multinational group to which it belongs and has informed the Moroccan tax authorities accordingly.
In addition, this obligation applies to any company subject to corporate income tax in Morocco and held directly or indirectly by a company located in a country that has entered into an agree ment with Morocco, permitting the exchange of information for tax purposes through which it is required to file a CBCR pursu ant to the legislation in force in such country, or which would be required to file such report if it were located in Morocco, when informed by the tax administration of the failure of said country to exchange information due to the suspension of automatic exchange or to the persistent neglect of the automatic transmis sion to Morocco of the CBCRs in its possession.
Finally, if two or more enterprises subject to Moroccan corporate income tax that belong to the same multinational group are sub ject to the Moroccan CBCR requirements, one of them can be appointed by the group to submit the declaration on behalf of the others within the allowed deadline and in accordance with the aforementioned procedure if it informs the tax authorities before hand.
Failure to declare or file such report is punishable by a MAD500,000 fine.
Mergers and liquidations. The Moroccan Tax Code provides two types of taxation for mergers, which are the common tax regime and the specific regime.
Under the common tax regime, the absorbed company is subject to tax on all profits and capital gains relating to the merger and on the profits realized between the beginning of the fiscal year and the effective date of the merger.
The specific regime, which was made permanent by the 2017 Finance Law, allows deferred taxation of profits related to good will and land, if certain conditions are met. This preferential regime also provides additional incentives such as an exemption for profits derived from share transfers at the level of the share holders. The preferential regime also applies to total scissions (demergers) of companies.
Liquidations of companies trigger immediate taxation in accor dance with the tax rules described above and, if applicable, a 15% withholding tax on liquidation profit called “Boni de liquidation.”
The “Boni de liquidation” is the balance of assets that remains for shareholders on the liquidation of a company after settlement of all liabilities, and the reimbursement of the share capital and reserves aged more than 10 years.
F. Treaty withholding tax rates
Dividends Interest Royalties
% % %
Bulgaria 7/10 (c) 10 10
Canada 15 (e) 15 (e) 5/10
China Mainland 10 (e) 10 10
Côte d’Ivoire 10 10 10
Croatia 8/10 (k) 10 10
Czech Republic 10 (e) 10 10
Denmark 10/25 (e) 10 10
Egypt 10/12.5 (e) 10 10
Finland 7/10 (l) 10 10
France 15 (a)(e) 10/15 (e) 5/10
Gabon 15 10 10
Germany 5/15 (e) 10 10
Greece 5/10 (i) 10 10
Hungary 12 (e) 10 10
India 10 (e) 10 10
Indonesia 10 10 10
Ireland 6/10 (m) 10 10
Italy 10/15 (e) 10 5/10
Jordan 10 10 10
Korea (South) 5/10 (f) 10 5/10
Kuwait 2.5/5/10 (e) 10 10
Latvia 8/10 (k) 10 10 Lebanon 5/10 (h) 10 5/10 Luxembourg 10/15 (e) 10 10 Maghreb Arab
Union (d) (b) (b) (b)
Malaysia 5/10 (h) 10 10 Mali 5/10 (i) 10 10 Malta 6.5/10 (j) 10 10 Netherlands 10/25 (e) 10/25 (e) 10 North Macedonia 10 10 10
Norway 15 (e) 10 10
Oman 5/10 (h) 10 10
Pakistan 10 10 10
Poland 7/15 (c)(e) 10 10
Portugal 10/15 (e) 12 (e) 10
Qatar 5/10 (e) 10 (e) 10
Romania 10 (e) 10 10
Russian Federation 5/10 (f) 10 10 Senegal 10 10 10 Singapore 8/10 10 10
Spain 10/15 (e) 10 5/10
Switzerland 7/15 (c)(e) 10 10
Syria 7/15 10 10
Turkey 7/10 (c) 10 10
Ukraine 10 10 10
United Arab Emirates 5/10 (g) 10 10
United Kingdom 10/25 (e) 10 10
United States 10/15 (e) 15 (e) 10
Vietnam 10 10 10
Non-treaty jurisdictions 15 10 10
(a) No withholding tax is imposed in France if the recipient is subject to tax on the dividend in Morocco.
(b) Tax is payable in the country in which the recipient is domiciled.
(c) The 7% rate applies if the beneficiary of the dividends is a company, other than a partnership, that holds directly at least 25% of the capital of the payer of the dividends. The higher rate applies to other dividends.
(d) The Maghreb Arab Union countries are Algeria, Libya, Mauritania, Morocco and Tunisia.
(e) Under Moroccan domestic law, the withholding tax rate for interest is 10%. Consequently, for interest paid from Morocco, the treaty rates exceeding 10% do not apply. In addition, the domestic withholding tax rate for dividends is 15%, effective from 1 January 2013. Consequently, for dividends paid from Morocco, the treaty rates exceeding 15% do not apply.
(f) The 5% rate applies if the beneficiary of the dividends holds more than USD500,000 of the capital of the payer of the dividends. The 10% rate applies to other dividends.
(g) The 5% rate applies if the beneficiary of the dividends holds directly at least 10% of the capital of the payer of the dividends. The 10% rate applies to other dividends.
(h) The 5% rate applies if the beneficiary of the dividends is a company that holds directly at least 10% of the capital of the payer of the dividends. The 10% rate applies to other dividends.
(i) The 5% rate applies if the beneficiary of the dividends is a company, other than a partnership, that holds directly at least 25% of the capital of the payer of the dividends. The 10% rate applies to other dividends.
(j) The 6.5% rate applies if the beneficiary of the dividends is a company, other than a partnership, that holds directly at least 25% of the capital of the payer of the dividends. The 10% rate applies to other dividends.
(k) The 8% rate applies if the beneficial owner of the dividend is a company (other than a partnership) that holds directly at least 25% of the capital of the company paying the dividends. The 10% rate applies in all other cases.
(l) The 7% rate applies if the beneficial owner of the dividends is a company that holds directly at least 25% of the capital of the company paying the divi dends. The 10% rate applies in all other cases.
(m) The 6% rate applies if the beneficial owner of the dividends is a company that owns directly at least 25% of the capital of the company paying the dividends. The 10% rate applies in all other cases.
Morocco has ratified tax treaties with Albania, Azerbaijan, Cameroon, Estonia, Ethiopia, Ghana, Lithuania, Madagascar, Mauritius, Rwanda, São Tomé and Príncipe, Saudi Arabia, Serbia, Slovenia, South Sudan, Yemen and Zambia, but these treaties are not yet in force.
Morocco has signed tax treaties with Bangladesh, Burkina Faso, Congo (Republic of), Guinea-Bissau and Iran, but these treaties have not yet been ratified.