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Morocco Cross-Border Tax Guide

the Morocco cross-border taxation for 2026. The guide covers: the 183-day rule for the tax residency determination; the worldwide income taxation for the tax residents; the source-only income taxation for the non-residents; the treaty network of 40+ countries — including France, Spain, the United Arab Emirates, and the other major trading partners; the unilateral foreign tax credit (FTC); the OFS (Offshore Financial Services) regime for the financial services companies; and the Hassania hub for the international banking.

183-Day Residency Rule

  • 183-day test: The individual is considered the tax resident of Morocco if present in Morocco for 183 days or more (continuous or intermittent) during the calendar year. The day of arrival and the day of departure are both counted as the days of presence.
  • Consequences of residency: The tax resident is subject to the worldwide income taxation — the Impôt sur le Revenu (IR) at the progressive rates of 0-38% applies to the income from both the Moroccan and the foreign sources.

Worldwide Income for Residents

  • Territorial principle modified: Morocco follows the modified territorial principle. The residents are generally taxed on the Moroccan-source income. However, the worldwide income is taxable for the residents with the "centre of economic interests" in Morocco — the income from the foreign sources is also subject to the IR, with the credit for the foreign taxes paid.
  • Foreign tax credit (unilateral): The Morocco tax residents may claim the unilateral foreign tax credit (FTC) (the "crédit d'impôt étranger") for the taxes paid on the foreign-source income. The credit is limited to the Morocco tax payable on the foreign income (the per-country limitation).

Source-Only Taxation of Non-Residents

  • Non-residents — source-only: The non-residents (the "non-résidents" — the "non-residents") are taxed only on the Moroccan-source income. The foreign income is not subject to the Morocco tax for the non-residents.
  • Withholding tax regime: The Moroccan-source income paid to the non-residents is subject to the withholding tax (the "retenue à la source" — the "WHT") at the rates specified in the CGI (Code Général des Impôts — the General Tax Code). The typical rates: the dividends at 15%, the interest at 20%, the royalties at 10%, the services fees at 10-20%.

Treaty Network — 40+ Countries

  • Network: Morocco has concluded the double tax agreements (DTAs) with 40+ countries. The major treaty partners include: France, Spain, Belgium, Italy, the Netherlands, Germany, the United Kingdom, the United Arab Emirates, Saudi Arabia, Kuwait, Qatar, Egypt, Tunisia, Senegal, Côte d'Ivoire, and others.
  • Treaty benefits: The DTAs typically provide: (a) the reduced withholding tax rates on the dividends (0-10%), the interest (10-15%), and the royalties (5-10%), (b) the PE threshold of 3-6 months for the construction and the services, (c) the tiebreaker rules for the dual residency, (d) the exchange of information clauses.
  • Treaty relief: The non-resident must provide the Certificate of Residence (CoR) to claim the DTA benefits. The certificate must be certified by the home country tax authority.

Foreign Tax Credit — Unilateral

  • Unilateral credit availability: Morocco provides the unilateral foreign tax credit for the taxes paid abroad on the foreign-source income, regardless of whether the DTA exists with the source country.
  • Limitation: The FTC is limited to the lower of: (a) the foreign tax actually paid, or (b) the Morocco IR or IS (Impôt sur les Sociétés) attributable to the foreign-source income. The unused credit cannot be carried forward.

OFS — Offshore Financial Services Regime (Limited)

  • OFS regime — Casablanca Finance City: The OFS (Offshore Financial Services) regime, primarily based in the Casablanca Finance City (CFC), offers the preferential tax treatment for the qualifying financial services companies. The CFC is the financial hub designed to attract the international banks, the insurance companies, and the financial services firms.
  • Tax benefits: The CFC companies benefit from: (a) the corporate income tax (IS) at the reduced rate of 8.75% (instead of the standard 31% or 20%), (b) the full exemption from the withholding tax on the dividends and the interest paid to the non-residents, (c) the exemption from the VAT on the qualifying services, (d) the exemption from the professional tax (the "taxe professionnelle") for 5 years.
  • Requirements: The company must: (a) have the minimum share capital of MAD 1 million, (b) generate at least 50% of the turnover from the exports of the financial services, (c) maintain the substance and the local presence in Casablanca.

Hassania Hub for Banking

  • Hassania hub initiative: Morocco is developing the Hassania hub — the financial and the banking cluster designed to strengthen Morocco's position as the regional financial centre for the North and West Africa. The hub is closely linked to the Casablanca Finance City ecosystem.
  • International banking: The hub facilitates the cross-border banking operations, the trade finance, and the investment banking services for the international clients operating in the African markets. The tax incentives available under the CFC regime apply to the qualifying entities.