In brief: Government Head circular no. 15/2025 of 21 November 2025 sets out the Morocco Offshoring Offer, in force from 1 July 2025 to 31 December 2030. It provides for four measures: the AIR (the State bears employees’ income tax (IR) above 20% or 10% of gross taxable income), the AIS (coverage of 56% of the corporate tax (IS) rate applied to the exported share of profit), the PAE (17% of RBI per stable job created) and the PAF (3.5% of RBI as a training credit). These are not provisions of the CGI: the company pays IR and IS as usual, then the State refunds part of it in year N+1. Access depends on the segment, the export share, headcount and location.
What the Morocco Offshoring Offer 2025-2030 is
For background on the sector and its baseline tax regime, see our guide to service offshoring in Morocco. This article details the measures of Government Head circular no. 15/2025 of 21 November 2025, “Implementation of the Morocco Offshoring Offer”, issued under the “Digital Morocco 2030” strategy.
Key dates:
- entry into force on 1 July 2025;
- AIR and AIS applicable from the 2025 financial year;
- all four measures end on 31 December 2030.
It comes with six annexes, including the procedure manuals for the AIR, AIS, PAE and PAF (annexes 3 to 6), approved on 1 July 2025.
One point governs everything else: these measures are budgetary contributions and bonuses paid by the State after the fact. They change neither the income tax scale nor corporate tax rates. The company pays its employees’ IR and its own IS as usual, then submits a file the following year. The benefit for a given year arrives in the spring or summer of the next year at the earliest, and the cash-flow plan must allow for this.
Who is eligible: the five segments and the export and headcount criteria
The circular defines offshoring as the “relocation of certain business activities or processes to the Kingdom of Morocco”. It covers five segments:
- ITO: infrastructure management, software development, application maintenance (LAN/WAN networks, web and mobile, testing).
- CRM: customer reception, telemarketing, complaints and debt collection management, digital (help desk, B2C/B2B telesales).
- BPO: administrative and business functions (accounting and financial processing, tax returns, payroll, claims management).
- ESO: engineering, R&D, civil engineering (CAD, numerical simulation, embedded software, clinical research).
- KPO: market research, data analytics, specialised publishing, legal process outsourcing (financial modelling, translation, contract review).
This list (annex 1) is not exhaustive. For the 20% AIR, two common conditions apply. The first concerns the share of services turnover that is exported; year 1 is the first year of benefit under Circular 15/2025.
| Company profile | Year 1 | Year 2 | Year 3 | Year 4 | Years 5-6 |
|---|---|---|---|---|---|
| Newly created company | 20% | 20% | 50% | 70% | 70% |
| Operating company that has never benefited from the AIR (or for a single year) | 50% | 50% | 70% | 70% | 70% |
| Company that has already benefited from the 20% AIR for at least 3 years | 70% | 70% | 70% | 70% | 70% |
The second condition sets a minimum headcount per segment:
| Segment | New company | Company already a beneficiary or in existence for more than one year |
|---|---|---|
| CRM | 100 | 150 |
| BPO | 25 | 50 |
| ITO | 20 | 30 |
| ESO | 20 | 30 |
| KPO | 20 | 30 |
The other measures (10% AIR, AIS, PAE) require 70% of services turnover from exports and net job creation over six years, detailed below. The PAF has its own thresholds.
Where: P2I, outside a P2I, regions without a P2I
A P2I Offshoring (integrated industrial platform dedicated to offshoring) is an area reserved for offshoring, close to a major urban centre, with flexible real estate and a one-stop shop. The main P2Is are Casanearshore in Casablanca and Technopolis in Rabat. The circular names Fès Shore, Oujda Shore and Tétouan Shore as secondary P2Is, “or any future new P2I Offshoring outside Rabat and Casablanca”.
Location determines which measures are available:
| Location | AIR | AIS | PAE | PAF |
|---|---|---|---|---|
| In a P2I Offshoring (Casablanca, Rabat, secondary P2Is) | Yes (20%; 10% in a secondary P2I) | Yes | Yes | Yes |
| Outside a P2I, in a region that has a P2I (ordinary office in Casablanca or Rabat) | No | No | Yes | Yes |
| Region without a P2I Offshoring | Yes (10% if specific criteria are met, otherwise 20%) | Yes | Yes | Yes |
The second row often comes as a surprise: a standard office in Casablanca, outside Casanearshore, gives no right to either the AIR or the AIS.
Setting up in a P2I requires an export commitment: at least 20% of services turnover in the first two years, 50% in the third, 70% from the fourth onwards. The file, submitted to the platform operator, is processed within 5 working days (25 if the CTO is consulted for an unlisted activity).
The P2I one-stop shop covers legal incorporation, residence permits for foreign employees, access to the measures and the online services of the CNSS and the DGI.
The AIR: State contribution on income tax above 20% or 10%
The AIR (income tax-related benefit) ensures that each employee’s income tax (IR) burden does not exceed 20% of their annual gross taxable income (RBI). The threshold falls to 10% for companies located in the secondary P2Is (Fès Shore, Tétouan Shore, Oujda Shore), or in a region without a P2I when they meet the specific criteria.
The calculation is done employee by employee:
- contribution = IR paid − (RBI × 20% or 10%), retained only if the result is positive;
- sum of the contributions for all employees;
- multiplication by the ratio Y = services export turnover / total turnover.
The IR taken into account is the amount actually paid to the Treasury, excluding penalties, according to the 9421 form and the payment slips.
For the 10% AIR, the company must meet the common criteria and, in addition, generate 70% of its services turnover from exports and achieve cumulative net job creation (CNE) over six years. T0 is the reference headcount. The thresholds are cumulative:
| Segment | T0 (never a beneficiary / already a beneficiary) | Year 1 | Year 2 | Year 3 | Year 4 | Years 5-6 |
|---|---|---|---|---|---|---|
| CRM | 100 / 300 | T0 + 60 | T0 + 120 | T0 + 210 | T0 + 300 | T0 + 420 |
| BPO | 20 / 100 | T0 + 20 | T0 + 40 | T0 + 70 | T0 + 100 | T0 + 140 |
| ITO | 20 / 100 | T0 + 20 | T0 + 40 | T0 + 70 | T0 + 100 | T0 + 140 |
| ESO | 20 / 50 | T0 + 10 | T0 + 20 | T0 + 35 | T0 + 50 | T0 + 70 |
| KPO | 20 / 50 | T0 + 10 | T0 + 20 | T0 + 35 | T0 + 50 | T0 + 70 |
Example. The calculation uses the 2026 salary income tax scale: 0% up to 40,000 DH, then 10%, 20%, 30%, 34% and 37% above 180,000 DH. Professional expenses of 25% capped at 35,000 DH, CNSS at 4.48% capped at 6,000 DH a month, AMO at 2.26%, employee with no dependants.
- An ITO engineer has an annual RBI of 400,000 DH. Their IR comes to about 103,100 DH, or 25.8% of RBI. The 20% AIR ceiling is 80,000 DH. The contribution is about 23,100 DH. With 90% of turnover from exports, the State pays about 20,800 DH for this employee.
- An employee has an RBI of 200,000 DH. Their IR is about 31,500 DH, or 15.7% of RBI. The 20% AIR produces nothing. The 10% AIR pays about 11,500 DH × Y.
The order of magnitude to remember: for an employee with no dependants, the 20% AIR only applies above roughly 255,000 DH of annual RBI. The 10% AIR applies from roughly 155,000 DH. The 20% AIR therefore targets high salaries: ITO, ESO, KPO, management. On a CRM floor with more modest salaries, it often has no effect. The 10% AIR in the secondary P2Is reaches a much larger share of the workforce.
The AIR cannot be combined with the State’s other investment-support schemes.
The AIS: 56% of the corporate tax rate covered
The AIS (corporate tax-related benefit) is State coverage of 56% of the corporate tax (IS) rate applied, on profit in proportion to exported services turnover. The formula in annex 4.1:
E = A × (B / C) × (IS rate × 56%)
- A = net taxable profit (positive);
- B = services export turnover;
- C = total taxable income;
- IS rate = the rate under the finance law in force applied to exports.
The criteria are those of the 10% AIR: 70% of services turnover from exports and cumulative net job creation over six years according to the same table. The AIS cannot be combined with other investment aid.
One exclusion deserves attention: a company whose minimum contribution exceeds its IS is not entitled to the AIS. A low-margin company whose minimum contribution exceeds the tax calculated on profit receives nothing.
The interaction with the CGI is simple once laid out. Article 6-II-B-4° fully exempts service outsourcing companies from IS for 5 financial years, then applies the 20% rate (see our IS exemptions). During the exemption, the rate applied is zero, so the AIS is zero. As soon as the 20% rate applies, the State covers 56% × 20% = 11.2 points. The company bears 8.8% on the exported share of its profit and 20% on the rest.
Example. Net taxable profit of 5,000,000 DH. Export turnover of 8,000,000 DH out of 10,000,000 DH of taxable income, i.e. 80%. IS at 20% = 1,000,000 DH.
- E = 5,000,000 × 0.8 × 11.2% = 448,000 DH;
- net IS borne: 552,000 DH, i.e. 11% of taxable profit (8.8% on the export share, 20% on the remaining 20%).
The AIS file adds the IS instalment slips and the certified tax return with the reconciliation table to the usual documents.
The PAE: 17% of RBI per stable job created
The Employment Bonus (PAE) equals 17% of annual RBI, capped at 300,000 DH per employee, for each new stable, direct and decent job. The job must meet all of these conditions:
- permanent, full-time contract;
- at least 18 consecutive months, i.e. a minimum of 468 days worked declared to the CNSS;
- employee of Moroccan nationality, declared to the CNSS.
The bonus is paid only once per employee over the whole term of the circular.
The company must carry out an offshoring activity, generate 70% of its services turnover from exports and achieve cumulative net job creation. The table in annex 5 starts from a T0 of 150 (CRM), 50 (BPO), 30 (ITO, ESO, KPO), then applies the same steps as for the 10% AIR: +60/+120/+210/+300/+420 for CRM, +20/+40/+70/+100/+140 for BPO and ITO, +10/+20/+35/+50/+70 for ESO and KPO.
Only net creation counts, T0 being the headcount at the end of the financial year preceding the first year of benefit. Support functions (HR, finance, legal, etc.), executives and intra-group transfers are excluded.
The formula: PAE = sum of the RBI of the employees retained × 17%. The number retained is the lower of cumulative net job creation minus employees already covered by a bonus, and employees who have reached 18 months and have not yet been covered. If there is a surplus, priority goes to the highest number of days worked, then to the highest RBI; the balance is carried forward.
The point to watch is timing: if no recruit has reached 18 months at the first submission, no bonus is paid that year.
Example. 40 eligible recruits with an average RBI of 90,000 DH: 40 × 90,000 × 17% = 612,000 DH.
The PAF: 3.5% of RBI as a training credit
The Training Bonus (PAF) equals 3.5% of annual RBI, capped at 300,000 DH, per new recruit of Moroccan nationality. It takes the form of a training credit per employee, opened on the recruitment date, paid each year and capped at 5 years. If the employee changes employer, they keep the remaining balance. The credit is granted only once per employee.
Conditions for the company:
- offshoring activity;
- share of services turnover from exports of 20% (years 1-2), 50% (year 3), 70% (years 4-6) for new companies or those that have never benefited from the DAF, and 70% for former DAF beneficiaries;
- minimum headcount at year end: CRM 100, BPO 20, ITO 20, ESO 20, KPO 20.
Conditions for the employee: permanent contract, at least 6 consecutive months full time declared to the CNSS, excluding support functions and executives.
The formula depends on the training provider:
- external training: per employee, min(RBI × 3.5%; training cost including VAT);
- in-house training centre: 80% of these amounts.
Training must be technical and linked to offshoring, with soft skills limited to 30% of training hours and a minimum of 18 days (144 hours) a year. The provider can be chosen freely (parent company, accredited institution, training firm, in-house centre). ANAPEC must be informed 72 hours before each session.
The PAF follows its own procedure: an annual certificate of eligibility issued by the AGCTN on a decision of the CTO, a commitment file lodged with ANAPEC, and a payment file between 31 March and 31 May of N+1.
Applications submitted under the former training aid scheme (DAF, Circular 08/2022) before 1 July 2025 remain governed by that circular.
Example. 40 recruits with an RBI of 90,000 DH, external training costing 4,000 DH including VAT each: min(3,150; 4,000) × 40 = 126,000 DH.
Procedure and timetable
For the AIR, AIS and PAE, the procedure is the same.
Submission. Between 31 March and 31 May of year N+1, to the AGCTN (Government Authority in charge of Digital Transition), against acknowledgement of receipt, and/or on the digital platform set up by the AGCTN. If the company applies for several measures for the same financial year, a single original of the common documents is enough.
AIR file. Application (annex 3.1 or 3.2), employee listing compatible with the 9421 form (annex 3.3), note on the components of RBI (3.4), sworn statement (3.5), certified 9421 form and monthly IR payment slips, certified tax return, certificates of total and export turnover, two CNSS certificates, tax compliance certificate, commercial register extract (model 7), bank details less than 3 months old. For the 10% AIR, a CNSS certificate of headcount at the end of N-1 is added.
Review. The CTO (Offshoring Technical Committee), chaired by the AGCTN and bringing together in particular the Budget department, the DGI, the CNSS and AMDIE, reviews and approves the files. It meets at least twice a month.
Payment. No later than 60 working days after the complete file is submitted.
Incomplete files. They may be cancelled 18 months after the first submission, after notification and a 60-working-day period to complete them.
Checks. An overstated contribution must be repaid within 60 working days, failing which eligibility is suspended. False documents expose the company to criminal prosecution.
For a 2025 financial year closed on 31 December, the file is submitted between 31 March and 31 May 2026. It relies on the 9421 form, the tax return and the CNSS declarations: these three sources must match.
Non-cumulation, transitional measures and end of the scheme
Non-cumulation. The AIR and AIS exclude other State investment aid. The PAE is excluded under a specific employment bonus agreement. The PAF excludes special training contracts (OFPPT) and ANAPEC employability programmes.
Transitional measures. A company that commits to setting up in a P2I may, exceptionally, benefit from the AIR and AIS before it is installed there. It needs an agreement or memorandum of understanding with the State and a promise to lease. The AIR then covers the staff it will fully relocate to the P2I. The benefit runs from the signing of the agreement until the premises are made available.
End of the scheme. All four measures end on 31 December 2030. A company that sets up a company in Morocco in offshoring must take this into account: exempt from IS for its first five financial years, a company created in 2026 will still be exempt in 2030 and will gain nothing from the AIS before the scheme expires, unless it is renewed. To compare set-up models, see nearshoring strategies.
What the press got wrong
“An effective IS rate of 11%”. The 11.2% figure is the share of the rate covered by the State (56% of 20%). It is not what the company pays. On the exported share of its profit, the company bears 8.8%. The 11% figure only appears when the export share and the rest are blended, as in the example above with 80% exports.
“56% from the 6th year”. The AIS applies as soon as IS is actually applied. For a new company exempt for 5 financial years under Article 6, this means from the 6th financial year. For a company already taxed at 20%, it is immediate, from the 2025 financial year.
“IR capped at 20%”. The scale does not change. The employer withholds and pays IR under the normal scale; in N+1 the State refunds the part above 20% (or 10%) of RBI, in proportion to exports.
Frequently asked questions
Does the Morocco Offshoring Offer replace the corporate tax exemption under Article 6 of the CGI?
No. Article 6-II-B-4° of the CGI still applies: full corporate tax (IS) exemption for 5 financial years, then a 20% rate. The AIS under Circular 15/2025 is a budgetary contribution that covers 56% of the IS rate applied. During the exemption, the rate applied is zero and the AIS is zero. It only takes effect once IS at 20% is actually due.
Can a company based in an office in Casablanca, outside a P2I, benefit from the AIR?
No. Outside a P2I Offshoring, in a region that has a P2I, such as Casablanca or Rabat, the company has access to neither the AIR nor the AIS. It remains eligible for the Employment Bonus (PAE) and the Training Bonus (PAF) if it meets their conditions. The AIR is, however, available in the P2Is and in regions that have no P2I Offshoring.
From what salary level does the 20% AIR have an effect?
For an employee with no dependants, income tax (IR) only exceeds 20% of gross taxable income above roughly 255,000 DH a year. Below that, the 20% AIR pays nothing. The 10% AIR, reserved for the secondary P2Is (Fès Shore, Oujda Shore, Tétouan Shore) and for regions without a P2I under specific criteria, applies from roughly 155,000 DH of annual RBI.
When and where are the files submitted?
AIR, AIS and PAE files are submitted between 31 March and 31 May of the year following the financial year concerned, to the Government Authority in charge of Digital Transition (AGCTN) or on its digital platform. The Offshoring Technical Committee (CTO) decides, and payment is made no later than 60 working days after the complete file is submitted. The PAF additionally requires an annual certificate of eligibility and a commitment file lodged with ANAPEC.
Can the measures be combined with the investment charter or special training contracts?
The AIR and AIS cannot be combined with the State’s other investment-support schemes. The PAE is excluded for the duration of a specific agreement concluded with the State for an employment bonus. The PAF can be combined neither with special training contracts (OFPPT) nor with ANAPEC employability programmes. A company that already receives State aid should check compatibility before submitting.
READ ALSO:
- Service offshoring in Morocco 2026: outsourcing, IAZ, CFC and taxation
- Corporate tax exemptions in Morocco 2026: which companies are really exempt?
- Salary income tax in Morocco: 2026 scale, calculation and exemptions
