In brief: Training or a seminar abroad is deductible from corporate tax (IS) (Art. 10-I-B of the 2026 CGI). When paid to a non-resident provider, it bears a 10% withholding tax excluding VAT (Art. 19-IV-B), subject to tax treaties, and a 20% self-assessed VAT (Art. 115).
A seminar in Paris raises four questions: the corporate tax deduction, the withholding tax on the payment to the foreign provider, Moroccan VAT on a service performed outside Morocco, and the income tax of the travelling employee. The 2026 General Tax Code (CGI) answers them through four different articles. Circular note no. 717 and two DGI rulings from 2003 and 2004 clarify the case of training abroad. The general rules are set out in our guide to deductible expenses for corporate tax in Morocco.
What the 2026 CGI says: deductibility, withholding tax and VAT
Corporate tax deduction (Art. 10-I-B and 11)
The law provides that “other external expenses incurred or borne for the needs of the business” are deductible (Art. 10-I-B). The place where the expense is incurred is not a condition of the text; only the link with the business counts.
In Morocco, seminar and training expenses abroad are deductible from corporate tax as other external expenses incurred for the needs of the business, under Article 10-I-B of the 2026 CGI.
Three limits frame this deduction:
- Supporting document (Art. 11-III): a regular invoice or other probative document “drawn up in the taxpayer’s name”, with the particulars of Art. 145. The add-back becomes final only if the document is not completed during the procedure of Art. 220 or 221.
- Payment (Art. 11-II): outside a crossed non-endorsable cheque, bill of exchange, magnetic means, bank transfer, electronic process or documented offsetting, the deduction is capped at MAD 5,000 per day and MAD 50,000 per month, per supplier (Finance Laws 2016 and 2019).
- Gratuitous benefit (Art. 11-IV): services “of a gratuitous nature” are not deductible.
Art. 146 covers purchases from a supplier subject to the business tax (taxe professionnelle). A Paris hotel or a provider established in France is not subject to it. For such documents, the textual basis is Art. 11-III. This articulation results from reading the texts; no doctrine reviewed states it.
Corporate tax territoriality (Art. 5)
The law provides that companies are taxable on profits from “profit-making operations they carry out in Morocco, even occasionally” (Art. 5-I). Non-resident companies are also taxable on the gross income of Art. 15 received for services rendered on behalf of persons “domiciled or carrying on a business in Morocco” (Art. 5-II). A foreign provider that trains the employees of a Moroccan company falls within this scope, even if the training takes place abroad.
Withholding tax (Art. 15, 19-IV-B and 160)
Art. 15 lists the gross income of non-residents subject to withholding tax. Four paragraphs concern training or a seminar:
| Art. 15 | Income covered |
|---|---|
| III | Study work carried out in Morocco or abroad |
| IV | Technical assistance or provision of personnel |
| IX | Commissions and fees |
| X | Services of any kind used in Morocco or supplied by non-resident persons |
In Morocco, the fee paid to a non-resident training provider bears a withholding tax of 10% of the amount excluding VAT, under Article 19-IV-B of the 2026 CGI, subject to the applicable tax treaty. The “excluding value added tax” base dates from the 2013 Finance Law. The tax is withheld by the payer (Art. 160); if the non-resident is paid by a non-resident third party, the tax is owed by the customer in Morocco (Art. 160-II).
VAT (Art. 88-2°, 99-A, 106, 112 and 115)
The law provides that a service is deemed carried out in Morocco when it is “exploited or used in Morocco” (Art. 88-2°). The criterion is the place of use, not the place of performance. The standard rate is 20% (Art. 99-A).
Where the non-resident provider has no accredited representative, the VAT is declared and paid by the customer (Art. 115, Finance Law 2014). A VAT-registered customer declares the amount excluding tax, calculates the tax and “at the same time deducts” it. A customer outside the scope of VAT withholds it at source (Art. 117-III). Since the 2026 Finance Law, the customer attaches a statement of non-resident taxpayers (Art. 112).
Art. 106-I-6° excludes from the right to deduct the VAT on “travel, reception or entertainment expenses”, except certain donations (Finance Law 2017). Art. 106-I-1° excludes services not used for the business, Art. 106-I-9° invoices not complying with Art. 146, and Art. 106-II repeats the MAD 5,000 per day and MAD 50,000 per month cash thresholds.
Employee income tax (Art. 56 and 57-1°)
Salary includes “benefits in cash or in kind granted in addition” (Art. 56). Allowances covering expenses incurred in the performance of the duties are exempt “to the extent that they are justified”, whether reimbursed on statements or paid as a lump sum (Art. 57-1°). Since the 2008 Finance Law, the exemption does not apply to employees benefiting from the professional expense rates of Art. 59-I-B and C.
Key takeaways:
- Seminar and training expenses abroad are deductible from corporate tax (Art. 10-I-B of the 2026 CGI), with a document in the company’s name (Art. 11-III).
- The fee paid to a non-resident provider bears a 10% withholding tax excluding VAT (Art. 19-IV-B of the 2026 CGI), subject to tax treaties.
- A service used in Morocco is subject to 20% VAT (Art. 88-2° and 99-A), self-assessed by a VAT-registered customer if there is no representative (Art. 115).
What the tax administration clarifies: NC 717 and NC 737
Travel, mission and training expenses
The administration states that travel, mission and reception expenses are deductible “provided they are justified by the nature or size of the business” and incurred “in the company’s interest” (NC 717, volume 1, p. 137). Training expenses are deductible “when they relate to the company’s purpose and are incurred in its interest and in the interest of the staff” (p. 142). The interest condition “excludes in particular expenses borne solely in the personal interest of certain shareholders” (p. 126).
Scope of the withholding tax
On Art. 15-X, the note covers “all services supplied or used in Morocco by non-resident individuals or legal entities” (NC 717, volume 1, p. 205). The rates in this part of the note are outdated; the text of Art. 15-X is identical in 2026. Only the definition of the scope is therefore used here; the rate is read in Art. 19-IV-B.
Employee expense allowances
The Art. 57-1° exemption requires expenses incurred in the performance of the duties, for an amount “in principle equivalent” to the expenses paid out, and justified (NC 717, volume 1, p. 320-322). On statement: breakdown, nature, period, amounts and receipts; a mission outside usual duties requires a written order. As a lump sum: nature, frequency, criteria and calculation method. Any excess over actual expenses is a “taxable supplement to remuneration”. See also our article on expense reports.
VAT on training abroad
For services, “the place where the service is rendered is not decisive” (NC 717, volume 2, p. 8-9). The note expressly covers training abroad: its taxation in Morocco depends on “the exploitation and use of the training on Moroccan territory” (volume 2, p. 10).
Excluded from deduction are travel and entertainment expenses, “accommodation, meals”, and the VAT on passenger transport by any means, air included, except a permanent staff transport contract (volume 2, p. 170).
Statement of non-residents and online services
NC 737 (Finance Law 2026, p. 31-32) comments on the statement of non-residents to be attached to the Art. 115 return; failure or delay is penalised under Art. 204-III. NC 735 (p. 30) and NC 736 (p. 41) comment on the overhaul of Art. 88-2° for digital services and on Art. 115 bis: they concern online training, not in-person training. Annual circular notes 729 to 737 do not deal with seminars or training abroad.
Key takeaways:
- According to NC 717 (volume 1, p. 137), travel and mission expenses are deductible if justified by the nature or size of the business.
- According to NC 717 (volume 2, p. 10), training attended abroad by staff is subject to VAT in Morocco because it is used there.
- Since the 2026 Finance Law (NC 737, p. 31-32), the statement of non-residents accompanies the Art. 115 return, failing which the Art. 204-III penalty applies.
Cases decided by the DGI: training, trips and seminars
Ruling no. 231 of 18/03/2004: staff training abroad
Question. Is staff training abroad subject to VAT and withholding tax (IS collection 2000-2005, p. 9-10)?
Answer. Without a treaty, the fee is subject to withholding tax. With a treaty, the treatment “is governed by treaty law, which generally provides for taxation at the rate of 10% by way of withholding tax”. For VAT, training is taxable in Morocco “as soon as this service is used in Morocco”.
In ruling no. 231 of 18/03/2004, the DGI accepted that staff training abroad is subject to VAT in Morocco as soon as it is used there.
2026 transposition. Predating the CGI (Law 24-86, Law 30-85), the ruling can be transposed under Art. 5-II, 15-X, 19-IV-B, 88-2° and 115. The wording “generally 10%” dates from 2004: the rate must be checked in the applicable treaty, for example the Morocco-France tax convention.
Ruling no. 474 of 20/11/2003: the Moroccan agency organising the trip
A Moroccan company acts as intermediary for trips and stays abroad of Moroccan customers (2003 collection, p. 58). The DGI treats this as a service carried out in Morocco, subject to VAT on the commission invoiced. The principle applies to an agency that organises a seminar abroad. The rate applicable in 2026 to travel agencies has not been checked here: only the principle is retained.
Ruling of 23/04/2015: the seminar in Morocco invoiced abroad
A Moroccan company holds seminars in Morocco, on behalf of a foreign company, for the staff of non-resident companies, invoiced abroad and paid in foreign currency. The DGI holds the profits taxable in Morocco (Art. 5-I), despite the invoicing, the foreign-currency payment and the foreign status of the participants.
The ruling also refused the “export of services” status. That part is abandoned: the IS export regime has been repealed (Finance Laws 2020 and 2023). This is the reverse of the case covered here. It only shows that the place of performance links the profit to Morocco. Individual ruling known through a 2019 private publisher’s sheet: indicative scope.
Key takeaways:
- DGI ruling no. 231 of 18/03/2004: staff training abroad bears withholding tax, subject to tax treaties, and Moroccan VAT if it is used in Morocco.
- DGI ruling no. 474 of 20/11/2003: the commission of a Moroccan company organising trips abroad is subject to VAT in Morocco.
- DGI ruling of 23/04/2015: a seminar held in Morocco on behalf of a foreign company is taxable in Morocco (Art. 5-I of the 2026 CGI); its “export” part is abandoned.
Application in 2026: worked example of a MAD 180,000 seminar in Paris
Assumptions: a VAT-registered Moroccan SARL sends employees to a training seminar in Paris. The MAD 180,000 excluding tax is invoiced in full by a provider established in France, with no establishment in Morocco, and paid by bank transfer. Hotel and flights are invoiced separately and not quantified.
| Item | 2026 treatment | Basis |
|---|---|---|
| Corporate tax (IS) | MAD 180,000 deductible if the training relates to the company’s purpose and is incurred in the interest of the company and staff; invoice in the company’s name, bank payment | Art. 10-I-B, 11-II, 11-III; NC 717 p. 137 and 142 |
| Withholding tax | 180,000 × 10% = MAD 18,000, on the amount excluding VAT, paid by the SARL; subject to the Morocco-France treaty | Art. 15-X, 19-IV-B, 160; ruling no. 231 |
| VAT on training | Used in Morocco: 180,000 × 20% = MAD 36,000 self-assessed and deducted at the same time; statement of non-residents attached | Art. 88-2°, 99-A, 112, 115; NC 717 vol. 2 p. 10; NC 737 p. 32 |
| VAT on hotel, meals, flights | No deductible VAT; liability to Moroccan VAT not settled by the texts | Art. 106-I-6°; NC 717 vol. 2 p. 170 |
| Employee income tax | No additional remuneration if written mission order and receipts; excess allowance taxable | Art. 57-1°; NC 717 p. 320-322 |
No total is calculated: the treaty treatment of the withholding tax and whether the SARL bears it (gross or net) are not settled by the texts reviewed. Self-assessed VAT is neutral if the simultaneous deduction applies; VAT on the hotel and flights remains a cost.
Requalification risk. Any personal leisure element paid by the company (accompanying person, tourist extension) risks being requalified as a benefit in kind (Art. 56) and as a non-deductible gratuitous benefit (Art. 11-IV). This risk is inferred from the texts; no doctrine reviewed settles it.
Key takeaways:
- For MAD 180,000 excluding tax invoiced by a provider established in France, the domestic withholding tax is MAD 18,000 (10%, Art. 19-IV-B of the 2026 CGI), subject to the treaty.
- The self-assessed VAT is MAD 36,000 (20%, Art. 99-A and 115), declared and deducted at the same time.
- VAT on the hotel, meals and flights is not deductible (Art. 106-I-6° of the 2026 CGI).
Points to watch
- Two distinct situations. Seminar in Morocco for foreigners: Art. 5-I. Training of a Moroccan employee abroad: Art. 5-II, 15-X and 88-2°.
- 10% withholding tax = domestic law. Always subject to the treaty with the provider’s country. The CGI does not describe it as final (libératoire).
- Foreign documents. Reference: Art. 11-III (document in the company’s name, particulars of Art. 145), as Art. 146 covers suppliers subject to the business tax.
- Statement of non-residents. Mandatory since the 2026 Finance Law; failure or delay penalised under Art. 204-III.
- Cash. MAD 5,000 per day and MAD 50,000 per month per supplier, for corporate tax (Art. 11-II) as for VAT (Art. 106-II).
- Online training. It falls under the digital services limb of Art. 88-2° (Finance Law 2025) and is analysed separately.
- Not settled by the texts. Withholding tax and Moroccan VAT on the hotel, meals and flights paid abroad; the payer bearing the withholding tax; any flat-rate scale for mission expenses.
Key takeaways:
- The training of a Moroccan employee abroad falls under Art. 5-II, 15-X and 88-2° of the 2026 CGI, not Art. 5-I.
- Since the 2026 Finance Law, failure to file the statement of non-residents is penalised under Art. 204-III.
- Cash payments are capped at MAD 5,000 per day and MAD 50,000 per month per supplier (Art. 11-II and 106-II).
Frequently asked questions
Is a seminar abroad deductible from corporate tax (IS)?
Yes, as an external expense incurred for the needs of the business (Art. 10-I-B). It must be justified by the nature or size of the business, incurred in the company’s interest (NC 717 p. 137) and supported by a document in the company’s name (Art. 11-III).
Must withholding tax be applied when the training provider is foreign?
Under domestic law, yes: 10% of the amount excluding VAT (Art. 15-X and 19-IV-B), according to DGI ruling no. 231 of 18/03/2004. A tax treaty may change this treatment.
Does Moroccan VAT apply to training attended abroad?
Yes, if the training is used in Morocco (Art. 88-2°; NC 717 vol. 2 p. 10). If the provider has no tax representative, the company self-assesses the VAT and deducts it at the same time (Art. 115). Since 2026 it attaches the statement of non-residents.
Is the VAT on hotels and plane tickets recoverable?
No. Travel, reception and entertainment expenses, accommodation, meals and passenger transport are excluded from the right to deduct (Art. 106-I-6°; NC 717 vol. 2 p. 170).
Are travel allowances paid to the employee subject to income tax (IR)?
No, if they cover justified actual expenses: written mission order, receipts (Art. 57-1°; NC 717 p. 321). Any excess over actual expenses is taxable as additional salary.
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