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.
|Individuals and non-qualified companies||Qualifying companies|
|Arab Maghreb Union (2)||(3)||(3)||(3)||(3)|
|China (People's Republic)||10||10||0/10||5/10|
|Korea (Republic of)||10||5||10||10|
|United Arab Emirates||10||5||10||10|
- 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.
- The member states of the Arab Maghreb Union are Algeria, Libya, Mauritania, Morocco, and Tunisia.
- There is no limitation on WHT under the treaty.
- 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.