Morocco Draft Finance Bill 2027: Proposed Tax Measures

Salaheddine YatimAbdelhakim Soudi

Salaheddine Yatim, Abdelhakim Soudi

Upsilon Consulting

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Morocco Draft Finance Bill 2027: Proposed Tax Measures

In brief: The draft finance bill 2027 proposes a 2031 target income tax scale that is exempt up to 60,000 DH and capped at 30% (37% under Article 73-I of the 2026 CGI), a 40% corporate tax rate on large hydrocarbon distributors and a 5% advance on imports.

The draft finance bill for the year 2027 was tabled in Parliament in October 2026. This article covers only the tax measures described in the explanatory note of the Ministry of Economy and Finance (Arabic version, pages 197 to 206) and compares them with the 2026 CGI and the 2026 finance law in Morocco. None of the following applies before the law is passed and published in the Official Bulletin. The article will be updated on promulgation.

The note organises the measures along two lines: completing the reforms of framework law no. 69-19 on tax reform, and creating a tax regime specific to the FIFA World Cup 2030.

Corporate tax: 40% rate on hydrocarbons and investment subsidies

MeasureBefore (2026 CGI)2027 bill
Companies importing or distributing hydrocarbon products, net profit equal to or above 100,000,000 DH35% (Art. 19-I-B)40%
Investment subsidy financing a non-depreciable asset other than land (example given in the note: goodwill)Allocated to the financial year of receipt (Art. 9-II)Spreading over 10 financial years possible

The 40% rate on hydrocarbons. The note cites the objective of framework law no. 69-19 to increase the contribution of companies engaged in regulated activities or in a monopoly or oligopoly position. The threshold remains that of Article 19-I-B: an annual net profit of at least 100,000,000 DH. In Morocco, this 35% rate has applied since the financial year opened on 1 January 2026, at the end of the transitional period of Article 247-XXXVII-A of the 2026 CGI. The 40% rate already exists for credit institutions and insurance companies (Art. 19-I-C). The general rules are set out in our guide to corporate tax in Morocco.

Investment subsidies. Article 9-II allows an investment subsidy to be spread over the depreciation period of the asset financed, or over ten financial years if it finances land. A subsidy allocated to another non-depreciable asset is taxed in the year of receipt. The bill extends the ten-year spreading to it.

Key takeaways:

  • The draft finance bill 2027 proposes a 40% corporate tax rate for companies importing or distributing hydrocarbons whose net profit reaches 100,000,000 DH, compared with 35% under Article 19-I-B of the 2026 CGI.
  • Investment subsidies financing non-depreciable assets other than land could be spread over 10 financial years (Article 9-II of the 2026 CGI).
  • The explanatory note does not state the effective date of these two measures.

Income tax: the progressive scale reformed from 2027 to 2031

The 2031 target scale

Annual brackets, in dirhams:

Before (Art. 73-I of the 2026 CGI)RateBill, 2031 target scaleRate
0 to 40,0000%0 to 60,0000%
40,001 to 60,00010%60,001 to 150,00010%
60,001 to 80,00020%150,001 to 500,00020%
80,001 to 100,00030%Above 500,00030%
100,001 to 180,00034%
Above 180,00037%

The objectives set for 2031 are as follows: exempt bracket raised from 40,000 to 60,000 DH, taxable brackets reduced from five to three, rates of 10%, 20% and 30%, marginal rate lowered from 37% to 30%. The reform would be implemented “gradually over five years (from 2027 to 2031)”. The note gives neither the 2027 scale nor those of the intermediate steps: an employee’s 2027 income tax therefore cannot be calculated from this document. The current scale is detailed in our article on salary income tax and the 2026 scale.

Expense allowances refocused by 2031

Article 57-1° of the 2026 CGI exempts allowances covering expenses incurred in the performance of the job, provided they are justified, reimbursed on statements or paid as flat amounts. The bill restricts the exemption to allowances that reimburse actual expenses, legally justified and borne exclusively on behalf of the employer. Allowances paid on a permanent basis in the ordinary performance of the job would become taxable salary supplements. This measure targets “the 2031 horizon”, together with the final scale. Until then, the list of allowances exempt from income tax still applies.

The bill also specifies that salary income (Article 56) includes all allowances and remuneration, whatever their description. The note does not date this clarification.

The flat-rate deduction for professional expenses raised to 45%

ParameterBefore (Art. 59-I of the 2026 CGI)2027 bill
Standard rate35% if annual taxable gross income does not exceed 78,000 DH; 25% above (Art. 59-I-A)45% for all employees
Cap35,000 DH35,000 DH
Category rates25%, 35% or 45% depending on the profession (Art. 59-I-B); 40% for seagoing staff in the merchant navy and fishing (Art. 59-I-C)45% for all
Combination with exempt allowancesExcluded for the categories of Art. 59-I-B and C (Art. 57-1°)Excluded for all by 2031

The note does not set the effective date of the 45% rate. Only the non-combination rule is dated.

Key takeaways:

  • The draft finance bill 2027 sets a target income tax scale for 2031: 0% up to 60,000 DH, then 10%, 20% and 30% above 500,000 DH, compared with six brackets and a top rate of 37% under Article 73-I of the 2026 CGI.
  • The explanatory note does not publish the scale applicable in 2027: the reform is spread from 2027 to 2031.
  • The flat-rate deduction for professional expenses would rise to 45% for all employees, capped at 35,000 DH, compared with 35% or 25% under Article 59-I-A.

Income tax: gains on securities and the informal sector

Disposals of securities not registered in an account. An individual who sells securities not registered with an authorised financial intermediary, for example shares in an unlisted company, currently files an annual declaration before 1 April (Article 84-I) and has paid the tax within 30 days of each disposal since the 2026 finance law (Article 173-I). The bill aligns the declaration with the payment: one declaration per disposal, filed with the payment during the month following that of the disposal. The regime for these gains is presented in our article on income from securities.

Bringing the informal sector into the system. Article 247-XVIII of the 2026 CGI taxes taxpayers who register for the first time, through enrolment on the business tax roll, only on their subsequent income and operations. This scheme applied from 1 January to 31 December 2022. The bill reintroduces it for 2027.

Key takeaways:

  • The draft finance bill 2027 would replace the annual declaration of gains on securities not registered in an account (Article 84-I, before 1 April) with one declaration per disposal, during the following month.
  • The measure of Article 247-XVIII of the 2026 CGI for newly registered taxpayers would be renewed for 2027.

VAT: livestock imports, withholding at source, property dealers and sand

MeasureBefore (2026 CGI)2027 bill
Imports of live domestic animals (cattle, sheep, goats, camelids) and their fresh, chilled or frozen meat and offalExemption from 1 January to 31 December 2026, limited to cattle (300,000 head) and camelids (10,000 head) (Art. 247-XXXXV)Permanent exemption; the note does not mention a quota
VAT withheld at source by the customerRefundable credit under decree no. 2-06-574 (Art. 117-IV and V)Withholding credited by the supplier against its VAT due; any excess refundable on request
Resale of built property by a property dealerOutside the scope: only construction works, land subdivision and property development are mandatorily taxable (Art. 89-I-4°)Special regime by option
Sales of sandNo specific provision in the 2026 CGIExemption without right to deduct

VAT withheld at source. Articles 117-IV and 117-V require certain customers to withhold the VAT of their suppliers of capital goods, works or services, which can create a credit that cannot be offset. The bill turns the withholding into a payment on behalf of the supplier, credited against its VAT for the period; the excess becomes refundable on request, using a form issued by the administration. The current mechanism is described in our article on VAT withholding at source.

Property dealers. Since the resale of property by a property dealer is outside the scope of VAT, the VAT paid on its works is not deductible. The bill gives the dealer an option for VAT in order to recover the tax on restoration, renovation or repair expenses. The note describes neither the terms of the option nor the taxable base. See our article on VAT on real estate operations.

Key takeaways:

  • The draft finance bill 2027 proposes a permanent VAT exemption on imports of live cattle, sheep, goats and camelids and their meat and offal, instead of a quota-based exemption limited to 2026 (Article 247-XXXXV of the 2026 CGI).
  • VAT withheld at source (Articles 117-IV and V) would be credited by the supplier against its VAT due, with any excess refundable on request.
  • Dealers in built property could opt for VAT; sales of sand would be exempt without right to deduct.

Registration and stamp duties: time-barred deeds, certificate and luxury tax

MeasureBefore (2026 CGI)2027 bill
Time-barred deed presented by the parties for registrationDuties, penalty and surcharges time-barred after 10 years (Art. 234-I-1°)Standard rate in force on the date of registration, without penalty or surcharges
Registration certificateRequired by the land registrar (Art. 139-I)Extended to all registered deeds and agreements
Stamp duties on first registration (luxury tax)5% from 400,000 to 600,000 DH; 10% from 600,001 to 800,000 DH; 15% from 800,001 to 1,000,000 DH; 20% above (Art. 252-I-C)Revision announced; new rates not stated (the two tables in the note are identical)

Time-barred deeds. After ten years, the administration can no longer claim the duties on an unregistered deed of its own motion, but the parties may request its registration. The bill sets the rate applicable in that case. Current rates are detailed in our article on registration duties in Morocco in 2026.

The luxury tax. The note announces a revision of the rates due to the rise in luxury car prices, but the two tables it publishes, the current scale and the proposed scale, are identical. The new rates therefore cannot be stated at this stage.

Key takeaways:

  • The draft finance bill 2027 proposes that a deed time-barred for more than 10 years (Article 234-I of the 2026 CGI), presented for registration by the parties, bear the rate in force on the date of registration, without penalty or surcharges.
  • The registration certificate, currently required by the land registry (Article 139-I), would be issued for all registered deeds.
  • The revision of the luxury tax (Article 252-I-C) is announced without a usable scale in the explanatory note.

Common measures: 5% import advance, payments, audits and penalties

The tax advance on imports. The bill creates an advance of corporate tax and income tax paid by traders who import goods intended for resale in their original state:

  • 5% of the customs value, collected with customs duties for the 60 months following the first import;
  • thereafter, collected only from importers without a tax compliance certificate;
  • creditable against corporate tax instalments or the minimum income tax contribution, then against the tax due, with a right to refund;
  • assessed and collected like customs duties; excluded for customs economic regimes and capital goods.
MeasureBefore (2026 CGI)2027 bill
Bank deposit as a means of paymentListed in Art. 193, absent from Art. 11-II and 106-IIAdded to Art. 11-II and 106-II
Competent local taxation commissionRegistered office, principal establishment or tax domicile of the taxpayer (Art. 225)Location of the property or business (real estate gains, registration and stamp duties); registered office of the issuing company (shares in unlisted real estate-dominant companies)
Capital gains in Morocco of a non-resident company without an establishmentDeclaration within 30 days following the month of disposal (Art. 20-III)Accelerated procedure (Art. 221) and National Tax Appeal Commission (Art. 226)

Procedures and penalties. The bill also provides for:

  • a right of reply for the taxpayer in the regularisation of withholding tax (Art. 222);
  • ex officio assessment under Article 228 for failure to declare salaries, pensions, dividends, fixed-income investment income, Sukuk income, remuneration of non-residents and gains on securities subject to withholding, with the repeal of Article 230 ter;
  • regularisation without procedure of withholdings declared but not paid over;
  • jurisdiction of the regional commissions (Art. 225 bis) set at the registered office of the issuing company for gains on Moroccan securities not subject to withholding;
  • extension of the right of disclosure (Art. 214-I) to collection and litigation;
  • repeal of Article 207 bis-VI (100 DH, then 250 DH per offence, maximum 500 DH per day, in stamp duties) in favour of the daily penalty of Article 185-I (500 DH per day, capped at 50,000 DH);
  • repeal of Article 230, which duplicates Article 229.

See also our article on tax audits in Morocco.

Key takeaways:

  • The draft finance bill 2027 creates an advance of corporate tax or income tax of 5% of the customs value for traders importing goods resold in their original state, collected for 60 months after the first import, creditable and refundable.
  • Bank deposit, already accepted under Article 193 of the 2026 CGI, would be added to the means of payment of Articles 11-II and 106-II.
  • Refusal to disclose information would be penalised for all taxes by the daily penalty of 500 DH per day capped at 50,000 DH (Article 185-I).

FIFA World Cup 2030: a temporary tax regime from 1 January 2027

The second line writes into the CGI the tax guarantees granted by Morocco to FIFA. This “incentive, exceptional and temporary” regime would apply from 1 January 2027 to events linked to the competition held in Morocco.

  • Taxes: temporary exemptions from corporate tax, the social solidarity contribution on profits and income, withholding tax, VAT and registration duties.
  • Beneficiaries, whether or not they have a registered office in Morocco: FIFA, its delivery entities and subsidiaries; the host federation, the co-organising federations, the host federations that are members of CONMEBOL, the member confederations and federations; the host broadcaster, and FIFA’s service providers and contractors appearing on the lists it draws up.
  • Income tax: temporary exemption of competition-related remuneration paid to persons seconded to Morocco, volunteers and non-resident players.
  • Other taxes: temporary benefits for stamp duties, the special annual tax on vehicles, the tax on insurance contracts and the air solidarity and tourism promotion tax.
  • Legacy fund of the competition, with a social purpose: full and permanent exemption.

Key takeaways:

  • The draft finance bill 2027 provides for a temporary tax regime for the FIFA World Cup 2030, applicable from 1 January 2027.
  • FIFA and its partners would be temporarily exempt from corporate tax, the social solidarity contribution, withholding tax, VAT and registration duties.
  • The explanatory note does not set an end date for the regime.

What remains to be confirmed

  • The vote and amendments: Parliament may amend, add or remove measures. The figures in this article are those of the bill as presented.
  • Effective dates: the note gives only four (income tax scale from 2027 to 2031, allowances and non-combination by 2031, informal sector in 2027, FIFA regime from 1 January 2027). For the other measures, the date is not specified in the explanatory note.
  • The 2027 income tax scale and the 2028 to 2030 steps: absent from the note.
  • The luxury tax: new scale to be read in the text of the bill or the law.
  • The terms of the VAT option for property dealers, of the refund of withheld VAT and of the FIFA regime.

Until promulgation, the 2026 CGI remains the only applicable text.

Frequently asked questions

Does the new income tax scale apply from 1 January 2027?

Not in full. The bill proposes a gradual revision from 2027 to 2031. The scale presented (0% up to 60,000 DH, then 10%, 20% and 30%) is the 2031 target. The explanatory note does not set out the step applicable in 2027.

What corporate tax rate does the draft finance bill 2027 propose for hydrocarbon distributors?

40%, instead of 35%, for companies importing or distributing hydrocarbon products whose annual net profit is at least 100,000,000 DH. The 35% rate of Article 19-I-B of the 2026 CGI would remain the rate for other companies above this threshold.

What does the bill change for the deduction of employees’ professional expenses?

The bill raises the flat rate to 45% for all employees, with the cap unchanged at 35,000 DH. Today, Article 59-I-A provides 35% up to 78,000 DH of gross income and 25% above. By 2031, this rate could not be combined with exempt allowances.

What is the 5% advance on imports proposed by the draft finance bill 2027?

An advance of corporate tax or income tax equal to 5% of the customs value, paid with customs duties by traders who import goods resold in their original state. It would apply for 60 months after the first import, then only without a tax compliance certificate. It is creditable and refundable.

Do the measures of the draft finance bill 2027 already apply?

No. A draft finance bill has no effect until it is passed by Parliament, promulgated and published in the Official Bulletin. The measures may be amended during the debate. Until then, the 2026 CGI remains the only applicable text.


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Frequently asked questions

Does the new income tax scale apply from 1 January 2027?
Not in full. The bill proposes a gradual revision from 2027 to 2031. The scale presented (0% up to 60,000 DH, then 10%, 20% and 30%) is the 2031 target. The explanatory note does not set out the step applicable in 2027.
What corporate tax rate does the draft finance bill 2027 propose for hydrocarbon distributors?
40%, instead of 35%, for companies importing or distributing hydrocarbon products whose annual net profit is at least 100,000,000 DH. The 35% rate of Article 19-I-B of the 2026 CGI would remain the rate for other companies above this threshold.
What does the bill change for the deduction of employees' professional expenses?
The bill raises the flat rate to 45% for all employees, with the cap unchanged at 35,000 DH. Today, Article 59-I-A provides 35% up to 78,000 DH of gross income and 25% above. By 2031, this rate could not be combined with exempt allowances.
What is the 5% advance on imports proposed by the draft finance bill 2027?
An advance of corporate tax or income tax equal to 5% of the customs value, paid with customs duties by traders who import goods resold in their original state. It would apply for 60 months after the first import, then only without a tax compliance certificate. It is creditable and refundable.
Do the measures of the draft finance bill 2027 already apply?
No. A draft finance bill has no effect until it is passed by Parliament, promulgated and published in the Official Bulletin. The measures may be amended during the debate. Until then, the 2026 CGI remains the only applicable text.

Upsilon

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