Morocco

Corporate - Withholding taxes

Last reviewed - 06 September 2019

WHT on dividends

The standard WHT rate on dividends is set at 15% according to the Moroccan law (unless reduced by treaty).

WHT does not apply to dividends paid to Moroccan companies subject to Moroccan CIT, subject to the delivery of a property attestation.

A branch tax of 15% applies to the net income transferred by the Moroccan branch to foreign entities (may be reduced by the tax treaty).

WHT on interests

The standard WHT on interest paid to non-resident entities is set at 10% as provided by the Moroccan law (unless reduced by treaty). However, the Moroccan law provides that interest on loans granted in foreign currency with a maturity exceeding ten years is exempt from WHT.

WHT on services paid to non-resident entities

According to the Moroccan Tax Code, all payments of all kinds of services rendered by non-resident entities are subject to WHT at the rate of 10%.

However, it shall be noted that treaty dispositions limit the scope of application of WHT only to remunerations that constitute royalties. Such dispositions overrule the domestic tax law provided by the Moroccan law.

Treaty WHT rates

Payments to non-resident corporations and individuals are subject to WHT, as shown below.

Recipient WHT (%)
Dividends Interest (1) Royalties
Individuals and non-qualified companies Qualifying companies
Non-treaty 15 15 10 10
Treaty:        
Arab Maghreb Union (2) (3) (3) (3) (3)
Austria 10 5 10 10
Bahrain 10 5 10 10
Belgium 15 6.5 10 10
Bulgaria 10 7 10 10
Canada 15 10 10 5/10 (4)
China (People's Republic) 10 10 0/10 5/10
Czech Republic 10 10 10 10
Denmark 15 10 10 10
Egypt 12.5 10 10 10
Finland 15 10 10 10
France 15 15 10 5/10 (4)
Germany 15 5 10 10
Guinea Conakry 10 5 10 10
Hungary 12 10 10 10
India 10 10 10 10
Ireland 10 6 10 10
Italy 15 10 10 5/10 (4)
Ivory Coast 10 10 10 10
Jordan 10 10 10 10
Korea (Republic of) 10 5 10 10
Latvia 10 6 10 10
Lebanon 10 5 10 5/10 (4)
Luxembourg 15 10 10 10
Malaysia 10 5 0/10 10
Mali 10 5 10 10
Malta 10 6.5 0/10 10
Netherlands 15 10 10 10
Norway 15 10 10 10
Oman 10 5 0/10 10
Pakistan 10 10 10 10
Poland 15 7 10 10
Portugal 15 10 10 10
Qatar 10 5 0/10 10
Romania 10 10 10 10
Russia 10 5 10 10
Singapore 10 8 10 10
Spain 15 10 10 5/10 (4)
Switzerland 15 7 10 10
Syria 10 7 10 10
Turkey 10 7 10 10
Ukraine 10 10 10 10
United Arab Emirates 10 5 10 10
United Kingdom 15 10 10 10
United States 15 10 10 10

Notes

  1. Some treaties provide for an exemption for certain types of interest (e.g. interest paid to public bodies and institutions). Such exemptions are not dealt with in this treaty chart.
  2. The member states of the Arab Maghreb Union are Algeria, Libya, Mauritania, Morocco, and Tunisia.
  3. There is no limitation on WHT under the treaty.
  4. The lower rate (i.e. 5%) usually applies to copyright royalties and other similar payments in respect of the production or reproduction of any literary, artistic, or dramatic work (excluding cinematographic and television films), while the 10% rate applies to other types of royalties.