Finance Bill No. 60-26 for the 2027 budget year amends the General Tax Code through its Article 7, which also sets the effective dates. The analysis note of the Tax team of Upsilon Consulting, dated 26 October 2026, compares these measures with the 2026 CGI, quantifies them and discusses them. This page sets out the essentials; the full 24-page note can be downloaded as a PDF above.
Bill under discussion in Parliament: version of 26 October 2026. The measures described will apply only in the wording enacted and published in the Official Gazette. The text may be amended until its adoption, and only the Arabic version published in the Official Gazette will be authoritative.
Morocco 2027 Finance Bill: the key figures
| Figure | Proposed measure |
|---|---|
| MAD 60,000 | IR exempt bracket from 2027 (MAD 40,000 in 2026) |
| 30% | IR marginal rate in 2031 (37% in 2026) |
| 45% | Employees’ standard deduction for professional expenses from 2027 |
| 5% | Tax advance collected at customs on imports intended for resale |
Summary table of the tax measures
| Tax | Proposed measure | Effective date |
|---|---|---|
| IR | Tax scale overhauled in five stages: exempt bracket raised to MAD 60,000 from 2027, final scale at 0, 10, 20 and 30% in 2031 | Income for 2027 to 2031 |
| IR | Standard deduction for professional expenses raised to 45% for all employees, within the unchanged limit of MAD 35,000; seafarers keep 40%, with no ceiling | Income earned from 2027 |
| IR | Abolition of the combination of this deduction with the exemption of expense allowances | Income earned from 2031 |
| IR | Mandatory electronic filing for all filers of the global income return | Returns filed in 2027 |
| IR | Securities not registered in an account with authorised financial intermediaries: return and payment for each disposal, within the following month | Disposals from 2027 |
| IR | Voluntary identification: taxation only of income arising after registration | Registrations in 2027 |
| IS | 40% rate (instead of 35%) for importers and distributors of hydrocarbons whose net profit reaches MAD 100 million | Financial years opened from 2027 |
| IS | Ten-year spreading extended to subsidies for any non-depreciable asset | Subsidies received from 2027 |
| IS, VAT | Deposit into the supplier’s bank account accepted as a method of payment | 1 January 2027 |
| IS and IR | Advance of 5% of the customs value on imports intended for resale in their original state, for sixty months, creditable against the tax for the financial year | Imports from July 2027 |
| VAT | Option for property dealers in built property to be taxed on their margin, with deduction of the VAT on works | Sales from July 2027 |
| VAT | Exemption of sand, without right of deduction | 1 January 2027 |
| VAT | Permanent import exemption for live cattle, sheep, goats, camelids and their meat | 1 January 2027 |
| VAT | Credit arising from withholding tax: repayment on request | 1 January 2027 |
| Registration duties | Time-barred deeds: registration at the rates in force, without penalty or surcharge | 1 January 2027 |
| Stamp duty | One-fifth increase in the stamp duty on first registration of vehicles worth at least MAD 400,000 (6 to 24%); electric and hybrid vehicles still excluded | 1 January 2027 |
| Procedures | Real property gains and registration duties: local tax commission of the place where the property is located | Appeals lodged from 2027 |
| Procedures | Withholding taxes: thirty-day response period before reassessment; ex officio assessment extended to employers’ returns and to new withholding taxes | Procedures initiated from 2027 |
| 2030 World Cup | Temporary exemption regime for FIFA, its entities and their service providers | Periods from 2027 to 2032 |
Personal income tax (IR): income tax brackets cut in five stages to 2031
If adopted as drafted, the Bill will replace the current six-bracket scale with a final four-bracket scale in 2031 (0, 10, 20 and 30%), by way of a transitional scale for each of the years 2027 to 2030. The exempt bracket of the scale is raised to MAD 60,000 from 2027. The 2027 and 2028 stages mainly benefit middle incomes; those of 2029 to 2031 mainly benefit high incomes, whose marginal rate is reduced from 37% to 30%. The scale in force is detailed in our guide to salary income tax and the 2026 scale.
The proposed scales, bracket by bracket
| Annual net taxable income (MAD) | 2026 | 2027 | 2028 | 2029 | 2030 | 2031 |
|---|---|---|---|---|---|---|
| 0 to 40,000 | 0% | 0% | 0% | 0% | 0% | 0% |
| 40,001 to 60,000 | 10% | 0% | 0% | 0% | 0% | 0% |
| 60,001 to 80,000 | 20% | 10% | 10% | 10% | 10% | 10% |
| 80,001 to 100,000 | 30% | 20% | 10% | 10% | 10% | 10% |
| 100,001 to 130,000 | 34% | 34% | 25% | 10% | 10% | 10% |
| 130,001 to 150,000 | 34% | 34% | 25% | 20% | 10% | 10% |
| 150,001 to 180,000 | 34% | 34% | 25% | 20% | 20% | 20% |
| 180,001 to 200,000 | 37% | 37% | 25% | 20% | 20% | 20% |
| 200,001 to 500,000 | 37% | 37% | 37% | 35% | 30% | 20% |
| Above 500,000 | 37% | 37% | 37% | 35% | 30% | 30% |
Rate applied to the portion of income falling within each bracket. 2026: scale in force; 2027 to 2030: transitional scales; 2031: final scale. How to read: in 2029, the portion of income between MAD 100,001 and MAD 130,000 is taxed at 10%, compared with 34% in 2026.
The 2027 scale is only a first stage. It exempts the portion between MAD 40,000 and MAD 60,000, hitherto taxed at 10%, and lowers the next two brackets by ten points (from 20% to 10% between MAD 60,000 and MAD 80,000, and from 30% to 20% between MAD 80,000 and MAD 100,000). Above MAD 100,000, the rates remain unchanged in 2027. The Government presents the reform as the implementation of Framework Law No. 69-19: broadening the exempt population, easing the burden on the middle class and reducing the marginal rate, while preserving the progressive nature of the tax.
Annual tax by income level
| Net taxable income (MAD) | 2026 | 2027 | 2028 | 2029 | 2030 | 2031 | 2031 / 2026 |
|---|---|---|---|---|---|---|---|
| 60,000 | 2,000 | 0 | 0 | 0 | 0 | 0 | −100% |
| 80,000 | 6,000 | 2,000 | 2,000 | 2,000 | 2,000 | 2,000 | −67% |
| 100,000 | 12,000 | 6,000 | 4,000 | 4,000 | 4,000 | 4,000 | −67% |
| 150,000 | 29,000 | 23,000 | 16,500 | 11,000 | 9,000 | 9,000 | −69% |
| 200,000 | 46,600 | 40,600 | 29,000 | 21,000 | 19,000 | 19,000 | −59% |
| 300,000 | 83,600 | 77,600 | 66,000 | 56,000 | 49,000 | 39,000 | −53% |
| 500,000 | 157,600 | 151,600 | 140,000 | 126,000 | 109,000 | 79,000 | −50% |
| 1,000,000 | 342,600 | 336,600 | 325,000 | 301,000 | 259,000 | 229,000 | −33% |
Annual tax in MAD, before the reduction for family dependants, calculated bracket by bracket on the scales above (firm’s calculation).
In 2027, the saving is identical, MAD 6,000 a year (MAD 500 a month), for any income of at least MAD 100,000; it is proportionally much greater for modest incomes, the tax due on an income of MAD 80,000 being divided by three compared with 2026. By 2031, the saving in dirhams increases with income, while the relative saving decreases above MAD 150,000.
The reduction for family dependants is not amended: MAD 600 per dependant, up to a maximum of MAD 3,600. Two rules nevertheless follow the scale, because they refer to its exempt bracket. A child remains a dependant as long as his or her annual global income does not exceed that bracket: the ceiling would rise from MAD 40,000 to MAD 60,000 from 2027. A retiree whose only income consists of supplementary retirement pensions, paid by several annuity payers required to withhold tax at source, is exempt from filing a return where the total net taxable amount of those pensions does not exceed the exempt threshold: this exemption would also apply up to MAD 60,000.
Employees: 45% standard deduction from 2027
From January 2027 salaries onwards, all employees would deduct 45% of their gross taxable salary in respect of professional expenses, within the current limit of MAD 35,000 a year. Only seagoing personnel of the merchant navy and of sea fishing retain their own rate of 40%. Since the ceiling is reached at a gross salary of MAD 77,778, the measure benefits only gross annual salaries below MAD 140,000, for which the deduction is currently below MAD 35,000.
| Current law (2026 CGI) | Bill (income earned from 2027) | |
|---|---|---|
| Standard rate | 35% if the gross annual taxable salary does not exceed MAD 78,000, 25% above that amount | 45% for all persons other than seafarers |
| Ceiling | MAD 35,000 | MAD 35,000 |
| Specific rates | 25% (casinos and gaming clubs), 35% (night-shift newspaper printing, miners, artists), 45% (journalists, life insurance, travelling sales representatives, aircrew), 40% (seafarers) | Repealed: these professions fall under the standard rate; seafarers keep 40%, calculated on a base that includes their allowances |
Worked example from the note: gross annual taxable salary of MAD 100,000 (private-sector employee, no family dependants, social contributions not deducted for ease of reading). 2026: expenses at 25% = MAD 25,000, net income of MAD 75,000, tax of 2,000 + 15,000 × 20% = MAD 5,000. 2027: expenses at 45% capped at MAD 35,000, net income of MAD 65,000, tax of 5,000 × 10% = MAD 500. Result: MAD 4,500 less tax a year, of which MAD 3,500 results from the scale and MAD 1,000 from professional expenses. On the same basis, a gross salary of MAD 78,000 is no longer taxed (MAD 1,070 in 2026), a salary of MAD 120,000 bears MAD 3,000 instead of MAD 9,000, and above MAD 140,000 the saving is limited to the MAD 6,000 resulting from the scale.
The measure also removes a threshold effect. Currently, a gross salary of MAD 78,001 gives entitlement to a deduction of MAD 19,500, compared with MAD 27,300 for a salary of MAD 78,000, and bears MAD 780 of additional tax for one additional dirham of salary. The single rate eliminates this jump.
Expense allowances: a two-stage regime
The exemption of expense allowances (Article 57-1°) is rewritten for 2031, but the increase in the standard deduction changes its scope as early as 2027:
- From 2027 to 2030, the 2026 text remains applicable to income earned up to 31 December 2030. The professions that had a specific rate (staff of casinos and gaming clubs, night-shift newspaper printing workers, mine workers, artists, journalists, life insurance agents and inspectors, travelling sales representatives, aircrew) now fall under the standard rate and are no longer covered by the exclusion: for four years, they may combine the 45% deduction with exempt allowances. Only seafarers remain excluded.
- From 2031, only “specific allowances paid by the employer to employees to reimburse the actual and duly substantiated expenses that they have incurred exclusively in the employer’s interest” would be exempt. Allowances paid on a permanent basis for the normal performance of duties constitute salary supplements, and the exclusion covers all beneficiaries of the deduction under Article 59-I, that is to say all employees.
The explanatory memorandum confirms the intent: by 2031, the 45% deduction and exempt allowances can no longer be combined. Read literally, however, the 2031 Article 57-1° defines an exemption from which all employees appear to be excluded; this point, which concerns all employers, would merit clarification before the vote or, failing that, in the implementing administrative circular. In the same vein, Article 56 specifies that allowances and emoluments constitute employment income “whatever their nature or characterisation”.
Returns: universal electronic filing and disposals of securities
- Global income return. The Bill makes electronic filing mandatory for all filers under Article 82, including employees and retirees. No transitional measure is provided: the rule would apply to returns filed in 2027 in respect of 2026 income, before 1 March for non-business income and before 1 May for business income determined under the actual or simplified net profit regime.
- Securities not registered in an account. Currently, the tax is paid within thirty days of each disposal, and an annual summary return is due before 1 April of the following year. The Bill requires a return and payment for each disposal “within the month following the month in which the disposal took place”. Example from the note: for a disposal of company shares on 20 March 2027, return and payment by 30 April 2027 at the latest. The tax remains due on the net gain for the year, and the MAD 30,000 exemption threshold for disposals remains annual; any excess of the payments is repaid on an annual application.
- Contribution of securities to a holding company. The return becomes electronic, still within sixty days of the deed.
- Voluntary identification. An individual who already carries on an activity without being identified and who registers for business tax from 1 January 2027 would be taxed only on income earned and transactions carried out from that date, for the year 2027 only.
Corporate income tax (IS): 40% for the main hydrocarbons operators
Companies engaged in the import or distribution of hydrocarbons whose net profit reaches MAD 100 million would be taxed at 40%, like banks and insurance companies, instead of 35% at present. The measure applies to financial years opened on or after 1 January 2027, and the provisional instalments for those years are already calculated at 40%. The Bill refers to dahir having force of law No. 1-72-255 of 22 February 1973: the measure thus covers, at the very least, importers and distributors of motor fuels, fuel oil, butane, propane and natural gas motor fuel. The Government justifies the measure by the regulated nature of these activities, which are carried on in a monopoly or oligopoly situation.
Worked example from the note: distributor with a net profit of MAD 150 million. 2026 IS: 150 × 35% = MAD 52.5 million. 2027 IS: 150 × 40% = MAD 60 million, i.e. MAD 7.5 million more. With the 5% social solidarity contribution, the total charge rises from MAD 60 million to MAD 67.5 million, i.e. 45% of the profit.
The note identifies four uncertainties in the new rate: its overlap with the 35% rate, the absence of a rule for exiting the threshold, the position of companies for which the distribution of hydrocarbons is only one line of business, and that of importers and distributors of lubricants. The standard rates are presented in our guide to calculating corporate income tax.
Subsidies and payments by bank deposit
- Investment subsidies. Currently, the subsidy is taxed in the year of receipt; the company may spread it over the depreciation period of the asset financed or, where it finances land, over ten financial years. Allocated to another non-depreciable asset, such as goodwill, it is taxed in full. For subsidies received from 2027, the spreading over ten financial years also applies to a subsidy allocated to “the acquisition of other non-depreciable fixed assets”. Example from the note: for a subsidy of MAD 2 million financing goodwill, in a company taxed at 20%, the IS goes from MAD 400,000 in 2027 to MAD 40,000 a year for ten financial years; the total tax is identical, but its payment is spread over ten years.
- Bank deposit. Currently, an expense settled other than by non-endorsable crossed cheque, bill of exchange, magnetic means of payment, transfer, electronic process or set-off is deductible only up to MAD 5,000 per day and per supplier, without exceeding MAD 50,000 per month; the same rule limits the deduction of VAT. The Bill adds payment of cash into the supplier’s bank account to the accepted methods of payment, for IS as well as for VAT.
5% advance on imports intended for resale
From 1 July 2027, a company or trader importing goods intended for resale in their original state would pay at customs, on each import, an advance of 5% of the customs value, on account of the IS or IR for the financial year. The advance is credited against the tax for the financial year.
| Item | Proposed rule |
|---|---|
| Scope | Any import of goods intended for resale in their original state, by a company subject to IS or a trader subject to IR |
| Exclusions | Imports of capital goods; imports carried out under a customs economic procedure (customs warehouse, free industrial warehouse, temporary admission, temporary export, transit, processing under customs control, drawback…) |
| Duration | Sixty months from the first import transaction; thereafter, the advance applies only to an importer that does not present to customs a tax compliance certificate less than six months old |
| Base | 5% of the customs value used, or that would be used, for customs duties |
| Company subject to IS | Credited against the provisional instalments, then against the balance of IS for the financial year, “with a right to repayment”; no repayment procedure is provided |
| Trader subject to IR | Credited against the minimum tax, then against IR; balance repaid automatically on the basis of the global income return |
Worked example from the note: low-margin importing trader. Imports of MAD 10,000,000 a year in customs value, taxable profit of MAD 345,000, IS at 20% = MAD 69,000. Advance: 5% × 10,000,000 = MAD 500,000 a year, of which MAD 69,000 is credited against IS for the financial year. The annual excess of MAD 431,000 gives rise to a right to repayment, under a procedure and within a time limit that the Bill does not specify. The advance is absorbed by the tax for the financial year only if taxable profit reaches 25% of the customs value imported (at the 20% rate).
The Government presents the advance as a means of integrating the informal sector and broadening the tax base. For importing businesses, the point whose clarification matters most is the starting point of the sixty months: read as the first import ever made by the business, the rule would immediately exempt an importer established for more than five years that produces its certificate; read as the first import subject to the advance, it would apply to all importers until June 2032. The note also raises the question of how the IS advance is credited where the tax due is equal to the minimum tax.
VAT: property dealers, sand, livestock and withholding tax
- Dealers in built property (sales from 1 July 2027). A property dealer could opt for VAT calculated on its margin at the rate of 20% (the option presupposes that, without it, these sales are outside the scope), with deduction only of the VAT on its restoration, renovation or refurbishment works, never the VAT on the acquisition. The base is the margin including all taxes: sale price less the purchase price and acquisition costs; the VAT due represents 20/120 of it. The option follows the common rules of Article 90 (application on a prescribed form, effective thirty days after filing, maintained for at least three consecutive years, on all or part of the sales); the invoice bears the statement “Taxation under the margin scheme”. On the note’s calculation, the option reduces the tax burden only for a loss-making transaction, where the VAT-inclusive margin is less than 1.2 times the works excluding VAT. See also our article on VAT on real estate transactions.
- Sand. Sand, currently taxable at 20%, would be exempt without right of deduction: the VAT on the seller’s diesel, machinery and transport would become a cost. Imported sand remains taxed at 20%, since the import exemption is not extended to it. The current list of these exemptions is set out in our guide to VAT exemptions without right of deduction.
- Imported live animals and meat. The Bill exempts on import, without quota and without time limit, “live domestic animals of the bovine, ovine, caprine and camelid species, as well as fresh, chilled or frozen meat and offal of those species”. It takes over from the temporary 2026 exemption, limited to cattle (300,000 head) and camelids (10,000 head).
- VAT withholding tax. The credit of a supplier whose VAT has been withheld, currently refundable on a quarterly application and paid within three months of filing, would no longer be refunded: “the excess not offset is repaid to the supplier on request”, the request being filed after the quarter in which the excess arises. The repayment has no time limit for payment, and nothing is said about refund applications pending on 1 January 2027. The current mechanism is described in our article on VAT withholding tax.
Registration duties and stamp duty
- Time-barred deeds. A deed whose duties are time-barred and for which a party requests registration would bear the proportional or fixed duties “in force on the date on which the registration formality is completed”, without the penalty or the late-payment surcharges. Example from the note: for a private sale agreement more than ten years old, with duties of MAD 40,000 at the rate in force at the time of the formality and approximately 120 months late, the party pays MAD 40,000 instead of the MAD 75,800 that a calculation of sanctions over the entire period of delay would have produced. The current rates are presented in our guide to registration duties in 2026.
- Registration certificate. It would be issued for every deed registered from 1 January 2027, as proof of the formality and of payment of the duties.
- Stamp duty on first registration. The proportional stamp duty levied on the first registration of a vehicle acquired in Morocco, or on its customs clearance if it is imported by a person other than an authorised dealer, is increased by one fifth in each bracket from 1 January 2027. The brackets are unchanged, and vehicles with an electric engine or a hybrid engine remain excluded from this duty.
| Vehicle value excluding VAT | 2026 | 2027 Bill | Duty for a vehicle in the middle of the bracket (MAD) |
|---|---|---|---|
| MAD 400,000 to 600,000 | 5% | 6% | 500,000: 25,000 → 30,000 |
| MAD 600,001 to 800,000 | 10% | 12% | 700,000: 70,000 → 84,000 |
| MAD 800,001 to 1,000,000 | 15% | 18% | 900,000: 135,000 → 162,000 |
| Over MAD 1,000,000 | 20% | 24% | 1,200,000: 240,000 → 288,000 |
The rate of the bracket applies to the entire value of the vehicle. The scale retains a marked threshold effect, which the increase accentuates: a vehicle of MAD 600,000 would bear duty of MAD 36,000, and a vehicle of MAD 600,001 duty of approximately MAD 72,000.
Tax procedures: commissions, withholding taxes and ex officio assessment
- Appeal commissions. For real property gains on buildings, real rights or shares in transparent real estate companies, and for duties on deeds relating to such property or to goodwill, the competent local tax commission would be that of the place where the property is located (appeals lodged from 2027). Thus, an appeal concerning land located in Agadir and sold by a taxpayer domiciled in Casablanca will fall within the jurisdiction of the Agadir local tax commission.
- Reassessment of withholding taxes. Currently, the tax authorities notify the reassessment of a withholding tax by a simple information letter and issue the assessment immediately. The Bill invites the person responsible for the withholding to submit observations within thirty days of the notification; the assessment is issued only if there is no response or if the observations are rejected.
- Ex officio assessment. It would cover the taxpayer, the employer or the annuity payer, and would extend to the returns for wages and salaries, pensions, income from shares and company interests, income from fixed-income investments and sukuk income, and payments to non-residents, as well as to new withholding taxes, including VAT withholding tax. The separate procedure applying a 20% surcharge for failure to file salary and pension returns is repealed. Tax withheld and declared but not paid over is, by contrast, excluded from this procedure: it is issued for collection directly.
- Right to obtain information. It may be used for litigation and collection purposes, and no longer only for assessment and audit; the daily penalty of MAD 500, capped at MAD 50,000, sanctions failure to respond.
2030 World Cup: a time-limited exemption regime
The Bill creates a tax regime specific to the organisation of the 2030 World Cup, defined by category of entity and limited in time. The Government links it to the guarantees given during the bid.
| Entities | Exemptions | Period |
|---|---|---|
| FIFA, the Delivery Entity, the Co-delivery Entities, FIFA subsidiaries | IS and social solidarity contribution on all their activities; withholding taxes on the sums they receive; domestic VAT with right of deduction and import VAT; registration duties, stamp duty, taxes on vehicles, insurance and air tickets; exemption from filing the tax return | 1 January 2027 to 31 December 2032 |
| Royal Moroccan Football Federation (Host Association), co-host associations and CONMEBOL hosts | The same taxes, for activities related to the competition and its events only | 1 January 2027 to 31 December 2032 |
| Confederations (AFC, CAF, CONCACAF, CONMEBOL, OFC, UEFA) and FIFA member associations | The same taxes, for activities related to the competition | 1 January 2029 to 30 June 2031 |
| Host broadcaster and FIFA service providers | Withholding taxes on the sums received from FIFA entities; domestic VAT with right of deduction on their competition-related services rendered to those entities, and on their purchases | 1 January 2027 to 31 December 2031 |
| FIFA contractors | Withholding tax on competition-related licence fees; import VAT (subject to re-export or donation), transport and licences | 1 January 2027 to 31 December 2031 |
| Individuals | IR, subject to conditions, on remuneration and allowances paid by entities with no registered office in Morocco to seconded persons (including match officials), on sums paid to volunteers and on sums paid to non-resident players in connection with their participation in the competition | Remuneration and allowances earned from 2027 to 2031 |
The Bill also exempts, without time limit, the Legacy Fund “that may be established by FIFA” to ensure a lasting social benefit from the competition. For Moroccan businesses, the most concrete consequence concerns a service provider that appears on the list of service providers drawn up by FIFA: it invoices its competition-related services rendered to FIFA entities exempt from VAT, with right of deduction, and the resulting VAT credit is refundable under the export procedure.
Effective dates: the timeline
Most measures apply from 1 January 2027, but the Bill sets a specific date for fourteen groups of articles. Two measures enter into force only on 1 July 2027, and two others take full effect only in 2031.
| Milestone | Measure | Transactions concerned |
|---|---|---|
| 1 January 2027 | Transitional IR scale for 2027 | 2027 income |
| 1 January 2027 | Professional expenses at 45% | Income earned from that date |
| 1 January 2027 | IS at 40% for hydrocarbons operators | Financial years opened from that date, and their instalments |
| 1 January 2027 | Ten-year spreading of subsidies financing a non-depreciable asset | Subsidies received from that date |
| 1 January 2027 | Return and payment for each disposal of securities not registered in an account, annual repayment, contribution to a holding company | Disposals made from that date |
| 1 January 2027 | Registration certificate, Legacy Fund exemptions from registration duties | Deeds registered from that date |
| 1 January 2027 | Other Legacy Fund exemptions (IS, withholding taxes, stamp duty, vehicle and insurance taxes) | From that date, without further detail |
| 1 January 2027 | Jurisdiction of the local and regional tax commissions | Appeals lodged from that date |
| 1 January 2027 | Right of response in withholding tax matters, extended ex officio assessment | Procedures initiated from that date |
| 1 January 2027 | Stamp duty on high-end vehicles | From that date |
| 1 January 2027 | Repeals: Article 230, separate procedure for salary returns, stamp duty penalty relating to the right to obtain information | Repeal from that date |
| 1 January 2027 | All other measures, including referral to the national appeals commission for non-resident companies | Introductory wording of Article 7 |
| 1 July 2027 | 5% import advance (IS and IR) | Imports made from that date |
| 1 July 2027 | VAT on the margin of property dealers | Sales made from that date |
| 2027 to 2032 | 2030 World Cup regime | Periods specific to each category of entity |
| 1 January 2031 | Final IR scale, abolition of the combination of professional expenses and exempt allowances | Income earned from that date (for allowances) |
For a measure without its own date, the introductory wording of Article 7 sets only 1 January 2027, without designating the event to which that date attaches: payment of the expense or purchase (bank deposit), the formality (time-barred deeds), filing of the return (electronic filing), invoicing or receipt of payment (sand), the import (live animals), filing of the application (VAT repayment). The implementing administrative circular should specify, measure by measure, the event adopted.
Fourteen interpretation issues
The note identifies fourteen uncertainties in the text that would merit resolution during the parliamentary debate or, failing that, in the implementing administrative circular. Ranked according to their significance for businesses, the first seven are as follows:
- 5% advance (IS): right to repayment without procedure or time limit.
- 5% advance: starting point of the sixty months not dated.
- 5% advance (IS): capital goods not defined; minimum tax not mentioned.
- Allowances (2031): exemption rewritten, from which all employees appear to be excluded.
- IS at 40%: overlap with the 35% rate, no exit rule, mixed activities, lubricants.
- Property dealers’ margin: sales without the option, negative margin, non-refundable credit, deduction by the purchaser, date of the option.
- IR scales: income “earned” or “received” not specified.
The other seven concern the repayment of VAT withheld, sand invoiced in 2026 and paid for in 2027, time-barred deeds, the triggering event for the vehicle stamp duty, the investment project condition for subsidies, the effective date for contributions of securities, and the World Cup regime. The note details each one, with the clarification that would remove the uncertainty.
Download the full analysis note
The 24-page note sets out, for each measure, the rule in force, the proposed rule and the firm’s commentary, with all the worked examples: download the 2027 Finance Bill note as a PDF. The French original is also available: Projet de loi de finances 2027 : les modifications proposées du Code général des impôts (PDF, in French).
Limitations of the note. It analyses the French version of the Bill tabled in the House of Representatives, in the light of the 2026 CGI and the texts in force on 26 October 2026. The explanatory memorandum was consulted only to shed light on the Government’s intent. The worked examples are based on fictitious data, and no guarantee is given as to the position that the tax authorities will take or as to the assessment of the courts. The interpretation issues flag the points that the Bill leaves open; they prejudge neither the final wording nor the doctrine that the tax authorities will lay down. Quotations from the Finance Bill and the General Tax Code are the firm’s translations; only the Arabic text published in the Official Gazette is authoritative.
For the rules applicable in 2026, see the tax measures of the 2026 Finance Law; our first reading of the Bill, based on the Government’s explanatory memorandum, remains available in the article Morocco’s Draft Finance Bill 2027: the tax measures.
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