International Taxation of Interest in Morocco: Withholding Tax (WHT) & Tax Treaties 2026

The taxation of interest paid to non-residents from Morocco is a critical topic for businesses operating internationally. Under Article 15 of the General Tax Code (CGI), such interest is generally subject to a 10% withholding tax (WHT). However, significant exemptions exist, particularly for long-term foreign currency loans, and bilateral tax treaties can modify this rate. This detailed guide by iHub explores the regime applicable in 2026, country-specific treaty rates, the requirements of the General Instruction on Exchange Operations (IGOC), and provides a practical example for better understanding.

The Moroccan Legal Framework: CGI Article 15 (2026)

The Moroccan General Tax Code establishes a precise framework for the taxation of interest, differentiating between resident and non-resident beneficiaries.

Withholding Tax on Interest Paid to Non-Residents

Article 15 of the CGI stipulates a 10% withholding tax on Moroccan-source interest paid, made available, or credited to accounts of non-resident individuals or legal entities. This WHT constitutes a final tax for the non-resident, unless otherwise provided by a tax treaty. This 10% rate applies to all fixed-income investment products, including interest on loans, bonds, and term deposits.

General Regime for Residents

For resident beneficiaries in Morocco, the taxation differs: a 20% WHT as an advance payment for corporate entities subject to Corporate Income Tax (IS), and a 30% WHT for resident individuals, with an option for global declaration. For optimal tax management and immaculate accounting services, it is crucial to distinguish these regimes.

Exemption for Long-Term Foreign Currency Loans

To encourage long-term investments, Article 6-I-C-3° of the CGI grants a full exemption from withholding tax on interest related to foreign currency loans with a duration of 10 years or more. Cumulative conditions include the loan being denominated in foreign currency, an initial term of at least 10 years, the funds being repatriated to Morocco, and the borrower providing a certificate from the Office des Changes (Exchange Office).

Treaty Rates: Country Comparison

Bilateral tax treaties signed by Morocco can reduce the domestic WHT rate. It is always important to compare the domestic law rate (10%) with the treaty rate and apply the more favorable one. If the treaty rate is equal to or higher than the domestic rate, the 10% CGI rate applies.

• France: 10% for bank loans, 15% in other cases.
• Spain: 10% (single rate).
• Belgium: 10% (possible exemption for certain government loans).
• United Arab Emirates: 10% (recently entered into force).
• China: 10% (subject to beneficial owner conditions).
• United Kingdom: 10% (reduced rate upon justification of UK resident status).
• Canada: 15% (reduced to 10% for certain bank loans).

IGOC Rules: Framework for Cross-Border Interest Flows

The General Instruction on Exchange Operations (IGOC) issued by the Office des Changes specifically governs international interest transfers. A deep understanding of these rules is essential for compliance. Our experts in legal advisory & dispute resolution can assist you in this process.

External Loans

Interest on external loans contracted by Moroccan residents from non-resident lenders is freely transferable, subject to justification of the operation to the authorized intermediary bank and after applying the applicable WHT.

Loans from Non-Resident Shareholders

Interest on shareholder current accounts funded by non-resident shareholders is governed by Art. 10-II-A-2° of the CGI, with a maximum deductible rate based on the average interest rate of 6-month Treasury bonds. The transfer is subject to a tax compliance certificate issued by the DGI. For any questions related to startup legal status creation or statutory amendments, iHub offers its expertise.

Structured External Financing

For structured financing operations (syndication, international bonds, sukuk), the IGOC provides specific prior declaration procedures to the Office des Changes. Interest is transferable in the loan's currency, at the exchange rate on the day of transfer.

Case Study: Interest Paid to a Spanish Bank

Let's illustrate with a Moroccan company paying interest to a Spanish bank for a 5-year euro loan.

• Loan amount: 2,000,000 EUR
• Annual interest rate: 4.5%
• Gross annual interest: 90,000 EUR
• Duration: 5 years (not eligible for long-term exemption)

The domestic law rate (CGI Art. 15) is 10%. The Morocco-Spain treaty rate is also 10%. Therefore, the applicable rate is 10%.

Calculation: WHT = 90,000 EUR x 10% = 9,000 EUR

Net amount transferred to the Spanish bank: 81,000 EUR

The Moroccan company must declare and pay the 9,000 EUR WHT to the DGI within the month following the interest payment. The Spanish bank can then credit this withholding tax against its tax due in Spain.

Conditions for Applying Treaty Rates

To benefit from a reduced treaty rate, the non-resident must provide a tax residence certificate and prove their beneficial owner status. The Moroccan debtor company must also submit a declaration of remunerations paid to non-residents (form ADC040F). Limitation on Benefits (LOB) clauses in some treaties may restrict access to treaty benefits for residents meeting substance conditions.

Reporting Obligations and Timeline

The Moroccan company must apply the WHT at the time of payment, remit it to the Treasury within the following month (CGI Art. 160), and file the annual declaration of remunerations paid to non-resident third parties before April 1st of the following year. Rigorous management of these deadlines is essential to avoid penalties.

International interest taxation in Morocco is complex, yet manageable. By thoroughly understanding CGI rules, tax treaty specifics, and Office des Changes directives, businesses can optimize their financial flows while maintaining full compliance. iHub is ready to assist you with all your tax and financial challenges in Morocco.