International Interest Taxation in Morocco — Withholding Tax & Treaties 2026 | Upsilon Consulting

In brief: Interest paid to non-residents from Morocco is subject to a 10% withholding tax (WHT) under Article 15 of the General Tax Code (CGI). Exemptions apply to foreign currency loans with a term of 10 years or more. Bilateral tax treaties may further reduce the rate. This guide covers the 2026 regime, treaty rates by country, IGOC foreign exchange rules, and a concrete worked example.

The Moroccan legal framework: Article 15 CGI 2026

The Moroccan General Tax Code distinguishes several interest taxation regimes depending on the beneficiary’s status and the nature of the transaction.

Withholding tax on interest paid to non-residents

Article 15 of the CGI provides for a 10% withholding tax on Moroccan-source interest paid, made available, or credited to the account of non-resident individuals or legal entities. This withholding constitutes a final tax for the non-resident, unless a treaty provides otherwise.

The 10% rate applies to all fixed-income investment products, including loan interest, bonds, certificates of deposit, and term deposits.

Standard regime for residents

For resident beneficiaries in Morocco, the regime differs:

• 20% WHT as a corporate tax advance on interest received by legal entities subject to corporate tax (IS).
• 30% WHT as income tax for resident individuals, with the option of filing a comprehensive tax return.

Exemption for long-term foreign currency loans

Article 6-I-C-3° of the CGI grants a full withholding tax exemption on interest relating to foreign currency loans with a term of 10 years or more. This measure aims to encourage the use of long-term international financing to support productive investment in Morocco.

The cumulative conditions for this exemption are:

1. The loan must be denominated in foreign currency.
2. The initial contract term must be at least 10 years.
3. The funds must be effectively repatriated to Morocco.
4. The borrower must produce a certificate from the Office des Changes.

Treaty rates: country-by-country comparison

Bilateral tax treaties signed by Morocco may reduce the domestic WHT rate. Here are the main rates applicable to interest in 2026:

Country	Treaty rate	Notes
France	10% – 15%	10% for bank loans, 15% in other cases
Spain	10%	Single rate applicable to all types of interest
Belgium	10%	Possible exemption for certain government loans
United Arab Emirates	10%	Recently entered into force
China	10%	Applicable subject to beneficial owner condition
United Kingdom	10%	Reduced rate upon proof of UK resident status
Canada	15%	Standard rate, reduced to 10% for certain bank loans

Important: The taxpayer must always compare the domestic rate (10%) with the treaty rate and apply the more favourable one. When the treaty rate equals or exceeds the domestic rate, the CGI rate of 10% applies.

IGOC rules: framework for cross-border interest flows

The General Instruction on Foreign Exchange Operations (IGOC) governs interest transfers linked to the following operations:

External borrowings

Interest on external borrowings taken out by Moroccan residents from non-resident lenders is freely transferable, subject to justification of the transaction to the authorised intermediary bank. The transfer is made after applying the applicable WHT.

Non-resident shareholder loans

Current accounts funded by non-resident shareholders are subject to a specific regime. The related interest must comply with the maximum deductible interest rate set annually by decree of the Minister of Finance, based on the average rate of 6-month Treasury bonds of the previous year (Art. 10-II-A-2° CGI).

The transfer of interest is conditional upon the production of a tax compliance certificate issued by the General Tax Directorate (DGI).

Structured external financing

For structured financing operations (syndication, international bonds, sukuk), the IGOC provides for specific prior declaration procedures with the Office des Changes. Interest is transferable in the currency of the borrowing, at the exchange rate on the date of transfer.

Worked example: interest paid to a Spanish bank

Consider a Moroccan company paying interest to a Spanish bank under a 5-year euro-denominated loan.

Transaction data:

• Loan amount: EUR 2,000,000
• Annual interest rate: 4.5%
• Gross annual interest: EUR 90,000
• Term: 5 years (not eligible for Art. 6-I-C-3° exemption)

Application of the Morocco-Spain treaty rate:

• Domestic rate (Art. 15 CGI): 10%
• Morocco-Spain treaty rate: 10%
• Applicable rate: 10%

Calculation:

• WHT = EUR 90,000 x 10% = EUR 9,000
• Net amount transferred to the Spanish bank: EUR 81,000

The Moroccan company must declare and pay the EUR 9,000 WHT to the DGI within the month following the payment of the interest (Art. 160 CGI). The Spanish bank may credit this withholding against its tax liability in Spain under the double taxation treaty.

Conditions for applying the treaty rate

To benefit from the reduced rate provided by a tax treaty, the non-resident must satisfy several conditions:

1. Tax residence certificate: the beneficiary must provide a certificate of tax residence issued by the tax authority of their country of residence, covering the year of the interest payment.

2. Beneficial owner status: the interest beneficiary must be the beneficial owner within the meaning of the treaty. Shell structures without economic substance do not qualify for treaty benefits.

3. Prior declaration: the Moroccan debtor company must file a declaration of payments made to non-residents (form ADC040F) with the DGI.

4. Limitation period for claims: if the standard rate was initially applied, the non-resident has a statutory limitation period to claim a refund of the overpayment, subject to providing the required supporting documents.

5. Limitation on benefits clause: some recent treaties contain a LOB (Limitation on Benefits) clause that restricts access to treaty benefits to residents meeting substance requirements.

Reporting obligations and calendar

A Moroccan company paying interest to a non-resident must:

• Apply the WHT at the time of payment, making available, or crediting to account.
• Remit the WHT to the Treasury within the month following the payment of the interest (Art. 160 CGI).
• File the annual return of payments made to non-resident third parties by 1 April of the following year.

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Read also

• Withholding tax on interest in Morocco
• Morocco’s tax treaties
• Tax credit and double taxation

Reference: General Tax Code 2026, Articles 15, 6-I-C-3°, 10-II-A-2° and 160; General Instruction on Foreign Exchange Operations (IGOC); Bilateral tax treaties of Morocco — Upsilon Consulting, accounting firm in Casablanca.