Key takeaways: Dividends paid from Morocco to foreign shareholders are subject to a 15% withholding tax (11.25% transitional rate for 2025-2026). Bilateral tax treaties can reduce this rate to as low as 5%, 6.5% or 10% depending on the country and shareholding level. The General Instruction on Foreign Exchange Operations (IGOC) guarantees the free transfer of dividends to foreign investors subject to supporting documentation. This article covers the CGI 2026 framework, treaty rates by country, the parent-subsidiary exemption and practical repatriation procedures.
Introduction: dividends in international capital flows
Morocco attracts a growing volume of foreign direct investment (FDI). In 2025, net FDI flows exceeded MAD 25 billion, and the tax treatment of dividends distributed to non-resident shareholders is a central concern for investors. The applicable regime combines three regulatory layers: the General Tax Code (CGI), bilateral tax treaties and foreign exchange regulations (IGOC).
Understanding how these three levels interact enables investors to optimise the tax cost of profit repatriation while maintaining full regulatory compliance.
Domestic law: CGI 2026
15% withholding tax
Article 13 of the CGI subjects dividends, directors’ fees and other participation income distributed by a Moroccan company to a 15% withholding tax (WHT). This withholding is final for non-resident beneficiaries who do not have a permanent establishment in Morocco.
Under the transitional measures of the 2025-2026 Finance Act, the effective rate is reduced to 11.25% for distributions made between 1 January 2025 and 31 December 2026 (Article 19-IV of the CGI). This reduction applies automatically, with no special formalities required.
Parent-subsidiary exemption under corporate tax
When the receiving company is itself subject to corporate tax in Morocco and holds at least 5% of the share capital of the distributing company for a minimum of two years, the dividends received benefit from a 100% deduction under the parent-subsidiary regime (Article 6-I-C-1 of the CGI). This mechanism primarily concerns Moroccan holding companies with local subsidiaries, but its existence also influences the structuring of international groups established in Morocco.
Treaty rates by country
Bilateral tax treaties signed by Morocco allow the domestic WHT to be reduced. The applicable rate generally depends on the shareholding percentage held by the beneficial owner.
| Country | Shareholding ≥ 25% | Shareholding < 25% | Legal basis |
|---|---|---|---|
| France | 15% | 15% | FR-MA Treaty, Art. 12 |
| Spain | 10% | 15% | ES-MA Treaty, Art. 10 |
| Belgium | 6.5% | 15% | BE-MA Treaty, Art. 10 |
| United Arab Emirates | 5% | 10% | UAE-MA Treaty, Art. 10 |
| China | 10% | 10% | CN-MA Treaty, Art. 10 |
| United Kingdom | 10% | 15% | UK-MA Treaty, Art. 10 |
| United States | 15% (domestic law) | 15% (domestic law) | No tax treaty |
Note: In the absence of a treaty (as with the United States), the full domestic rate of 15% applies, with no possibility of a treaty reduction.
Conditions for applying the treaty rate
To benefit from a reduced treaty rate rather than the domestic rate, the non-resident shareholder must:
- Provide a tax residency certificate issued by the tax authority of their country of residence, dated in the year of distribution.
- Be the beneficial owner of the dividends (not merely an intermediary or agent).
- Submit the request to the Moroccan distributing company before the payment date of the dividends.
- Not have a permanent establishment in Morocco to which the dividends would be attributable.
The distributing company retains the tax residency certificate and makes it available to the tax authorities during any audit.
IGOC: FDI dividend transfer guarantee
The General Instruction on Foreign Exchange Operations guarantees foreign investors who have made a foreign-currency investment in Morocco the right to freely transfer dividends, net profits and liquidation proceeds to their country of residence, without any amount limitation.
Documents required for the transfer
The authorised intermediary bank requires the following documents:
- Minutes of the General Meeting approving the dividend distribution.
- DGI certificate confirming payment of the withholding tax.
- Proof of the initial investment in foreign currency (exchange slip or bank certificate).
- Transfer form completed by the distributing company.
The transfer is processed within an average of 5 to 10 business days after submission of the complete file.
Special case: Moroccans Residing Abroad (MRE)
Moroccans Residing Abroad (MRE) can invest in Morocco through convertible dirham accounts. Dividends from these investments are transferable under the same conditions as FDI investments, provided the initial investment was made from a convertible dirham account duly opened with a Moroccan bank.
This provision is particularly advantageous for MRE wishing to establish or acquire shareholdings in Moroccan companies while retaining the ability to repatriate the income generated.
Worked example: dividends paid to a Belgian shareholder
Scenario: A Moroccan SARL distributes MAD 1,000,000 in dividends to its Belgian shareholder holding 30% of the share capital (shareholding ≥ 25%).
| Item | Without treaty | With BE-MA treaty |
|---|---|---|
| Gross dividends | MAD 1,000,000 | MAD 1,000,000 |
| Applicable WHT rate | 15% | 6.5% |
| WHT withheld | MAD 150,000 | MAD 65,000 |
| Net dividends transferred | MAD 850,000 | MAD 935,000 |
| Tax saving | — | MAD 85,000 |
The Belgian shareholder saves MAD 85,000 by applying the treaty rate of 6.5% instead of the domestic rate of 15%. In Belgium, the Moroccan WHT gives rise to a foreign tax credit that can be set off against Belgian tax due on the same dividends, thereby avoiding double taxation.
Best practices for international groups
- Plan your structure ahead: choose the holding company jurisdiction based on available treaty rates.
- Document everything: retain tax residency certificates and IGOC supporting documents.
- Monitor changes: tax treaties are regularly renegotiated; verify applicable rates before each distribution.
- Consult a chartered accountant specialising in international taxation to secure the tax treatment and transfer process.
Conclusion
International dividend taxation in Morocco rests on a three-tier framework — CGI, bilateral treaties and IGOC — that offers welcome predictability for investors. Correct application of treaty rates and compliance with exchange control formalities can significantly reduce the tax cost of profit repatriation.
Read also
- Withholding tax on dividends in Morocco
- Foreign investment in Morocco
- Morocco tax treaties
- IGOC dividend transfer
- Foreign tax credit double taxation
References: General Tax Code 2026, Articles 13, 19 and 6-I-C-1; DGI Circular Note 717; General Instruction on Foreign Exchange Operations of the Exchange Office; Bilateral tax treaties published in the Official Gazette.
