In brief: Morocco’s Finance Law 2026 (No. 50-25) consolidates tax reforms initiated since 2023, introducing corporate tax exemptions for maritime transport, VAT reverse charge on industrial waste, withholding tax on rental income from July 2026, and extending the Social Solidarity Contribution (CSS) through 2028.
Finance Law No. 50-25 for fiscal year 2026 follows the structural tax reforms initiated since 2023, in line with the guidelines of Framework Law No. 69-19 on tax reform, adopted in 2021. This summary note, published by the General Directorate of Taxes, details all the tax measures introduced.
Since 2023, successive reforms have addressed corporate income tax (progressive rate unification over 2023-2026), VAT in Morocco (harmonisation around two rates over 2024-2026) and income tax (rate schedule revision in 2025). The 2026 Finance Law aims to consolidate the gains of these reforms and accelerate the pace toward Morocco’s emergence.
The Four Pillars of the 2026 Finance Law
The main tax measures of the 2026 Finance Law are structured around four pillars:
- Integration of the informal sector into the structured economy and the fight against tax fraud
- Improvement of the business environment and corporate competitiveness
- Adaptation of the tax system and harmonisation of tax rules
- Strengthening social cohesion
I – Measures Specific to Corporate Income Tax (IS)
Key corporate income tax (IS) changes under the 2026 Finance Law include:
- Permanent exemption from withholding tax on international maritime transport
- Adapted tax rate for transformed microfinance institutions (20% or 35% for five years)
- Simplified declaration process for non-resident real estate capital gains (30-day deadline)
1. Permanent Exemption from Withholding Tax on International Maritime Transport
Before the 2026 Finance Law, rental fees and similar remuneration paid to non-residents for the chartering, rental and maintenance of vessels used in international maritime transport were subject to withholding tax under corporate income tax at a rate of 10%.
Article 7 of the 2026 Finance Law established a permanent exemption from corporate income tax on these rental fees and similar remuneration for the chartering, rental and maintenance of vessels used in international maritime transport, paid to non-resident persons. This exemption is provided for in Article 6-I-C-6° of the CGI and applies from 1 January 2026.
2. Adapted Rate for Microfinance Institutions
Microcredit associations that transform into banks or finance companies could benefit from an incentive tax regime for their asset and liability transfer operations. However, the banks or finance companies created following this transformation were subject to corporate income tax at a rate of 40%, like other credit institutions.
The 2026 Finance Law provides that transformed microfinance institutions, established as public limited companies, benefit from standard corporate income tax rates (20% or 35%) for a period of five consecutive fiscal years from the first year of operation. This measure is provided for by Article 19-I-C of the CGI and applies to fiscal years beginning on or after 1 January 2026.
3. Simplified Declaration of Real Estate Capital Gains by Non-Resident Companies
Before the 2026 Finance Law, non-resident companies without an establishment in Morocco that carried out a property sale had to declare capital gains as part of the annual tax return.
Henceforth, the 2026 Finance Law establishes the obligation to file a declaration of capital gains resulting from the sale within thirty (30) days following the month of the sale, using a simplified form established by the tax authorities. Payment of the corporate income tax due must be made within the same time frame. These changes apply to capital gains resulting from property sales carried out from 1 January 2026.
II – Measures Specific to Income Tax (IR)
Key income tax (IR) changes in Morocco’s 2026 Finance Law:
- Mandatory 30-day payment for capital gains on transferable securities
- Revised CFC employee tax regime: 20% flat rate for up to 10 years
- 50% allowance on goodwill sales under the CPU regime (capped at MAD 1,000,000)
- Tax reduction for dependants increased from MAD 500 to MAD 600 per dependant
- CIMR supplementary pension exemption extended
1. Payment of Income Tax on Capital Gains from Transferable Securities
The 2026 Finance Law establishes the obligation to pay the amount of tax owed by the transferor for each securities sale transaction within thirty (30) days following the date of the sale. This payment is made using a payment slip established by the tax authorities.
Taxpayers must also file an annual summary return of all sales made during the year, before 1 April of the year following the year in which the sales were made. This return serves as a request for refund of any excess tax paid.
2. Revision of the Tax Regime for CFC Employees
The 2026 Finance Law revised the tax regime for employees of companies holding Casablanca Finance City (CFC) status. These employees may opt for a specific income tax rate of 20%, for a maximum period of ten (10) years, from the date they take up their position, whether continuous or discontinuous, without taking into account periods of work performed outside CFC-status companies.
These employees may also opt, using a form established by the tax authorities, through their employer, to be taxed according to the progressive income tax rate schedule before 1 February of the year concerned by the option request. To terminate this option, employees must submit a request to their employer before 1 February of the year concerned.
The new provisions apply to employees:
- Who took up their position from 1 January 2026
- Who have not exhausted the ten (10) year period as of 31 December 2025
- Who have exhausted the five (5) year period as of 31 December 2017, for the remaining duration
3. Allowance for Goodwill Sales (CPU Regime)
Individuals whose professional income is determined under the single professional contribution (CPU) regime and who do not have a pension scheme benefit from a 50% allowance on the amount of the capital gain realised or recognised on the intangible elements of the business goodwill, up to a limit of one million (1,000,000) dirhams, when they permanently cease their professional activity.
Condition: taxpayers must be at least sixty-five (65) years of age at the date of permanent cessation. This measure applies to goodwill sale or withdrawal operations carried out from 1 January 2026.
4. Increase in the Tax Reduction for Dependants
The 2026 Finance Law increased the annual amount of the income tax reduction for dependants from 500 to 600 dirhams per dependant of the taxpayer. The ceiling for this reduction was also increased from 3,000 to 3,600 dirhams, while maintaining the benefit of said reduction for six (6) dependants of the taxpayer. These provisions apply to income earned from 1 January 2026.
5. Exemption for CIMR Supplementary Pensions
The 2025 Finance Law had already introduced an income tax exemption, effective 1 January 2026, for retirement pensions and life annuities paid under basic retirement schemes. The 2026 Finance Law extended this exemption to retirement pensions and life annuities paid by the Moroccan Interprofessional Retirement Fund (CIMR) to private sector retirees, under group supplementary retirement insurance contracts, under the same conditions provided for in Article 28-III of the CGI. These provisions apply to pensions and life annuities earned from 1 January 2026.
III – Measures Specific to Value Added Tax (VAT)
Key VAT measures introduced by the 2026 Finance Law:
- Reverse charge mechanism on industrial waste and metals purchases
- VAT exemption on agricultural fertilisers (import and domestic supply)
- Alignment of capital goods exemption periods (36 + 24 months)
- New statement requirement for non-resident taxpayers
- Exemptions on short-cut pasta, blood derivatives, and live domestic animals
1. VAT Reverse Charge on Industrial Waste and Metals
The 2026 Finance Law established the obligation for industrial processing companies to apply the reverse charge mechanism for VAT on their purchases of new industrial waste, metals and other recovery materials. These companies must declare and pay the tax on their own turnover return, calculate the tax due and proceed with deducting the amount of said tax.
Furthermore, the 2026 Finance Law exempted all metals and recovery materials from VAT, without the right to deduction. These measures apply to transactions carried out from 1 January 2026.
2. VAT Exemption for Agricultural Fertilisers
Before the 2026 Finance Law, certain types of fertilisers and growing media for agricultural use were excluded from the VAT exemption for domestic supply and importation. The 2026 Finance Law harmonised the tax treatment by introducing:
- VAT exemption on the importation of fertilisers and growing media, as defined by Law No. 53-18
- VAT exemption for domestic supply, with the right to deduction, for the same fertilisers and growing media
These exemptions take effect from 1 January 2026.
3. Alignment of Exemption Periods for Capital Goods
Before the 2026 Finance Law, the exemption period for capital goods for domestic supply and importation was 36 months, with additional periods that varied depending on the case. The 2026 Finance Law simplifies the framework: the exemption period of thirty-six (36) months, for domestic supply and importation, may be extended by an additional period of twenty-four (24) months, provided that an extension request is filed electronically before the expiry of the initial period.
These provisions apply to:
- Companies that sign their investment agreements with the State from 1 January 2026
- Companies that are building their investment projects and have not exhausted the 36-month period as of 31 December 2025
4. Statement of Non-Resident Taxpayers
The 2026 Finance Law provides that the client established in Morocco must attach to their own return, referred to in Article 115 of the CGI, a statement of non-resident taxpayers using a form established by the tax authorities. Failure to file this statement or late filing is subject to the penalties provided for in Article 204-III of the CGI.
5. Exemption for Short-Cut Pasta
The 2026 Finance Law exempted short-cut pasta, uncooked and unfilled, from VAT for domestic supply without the right to deduction and for importation, effective 1 January 2026. Taxable persons affected by the transitional provisions must submit by 1 March 2026 to the local tax office a list of debtor clients as of 31 December 2025.
6. Exemption for Blood and Blood Derivatives
The 2026 Finance Law introduced a VAT exemption for domestic supply with the right to deduction and for importation of blood (human and animal) and its derivatives, effective 1 January 2026.
7. Temporary Exemption for Live Domestic Animals
The 2026 Finance Law introduced a temporary VAT exemption on the importation of live domestic animals of bovine and camelid species, from 1 January 2026 to 31 December 2026, within a quota of 300,000 head and 10,000 head respectively.
IV – Measures Specific to Registration Duties and Stamp Duties (DET)
Key registration and stamp duty changes under Morocco’s 2026 Finance Law:
- Additional 2% duty on property transfers exceeding MAD 300,000 paid in cash without traceability
- Harmonised tax treatment of credit operations across all institutions
- 0.1% registration duty on public contracts
- Tax incentive regime for corporate group restructuring (fixed MAD 1,000 duty on current asset transfers)
- Reduction of share transfer duty from 6% to 5%
1. Additional 2% Registration Duty
The 2026 Finance Law established an additional registration duty of 2% on deeds transferring immovable property, real property rights or business goodwill, carried out without the ability to justify and trace payment methods, when the price exceeds three hundred thousand (300,000) dirhams in cash, or when the deed does not mention the payment methods and references. This provision applies to deeds and agreements executed from 1 July 2026.
2. Harmonisation of Tax Treatment of Credit Operations
The 2026 Finance Law harmonises the treatment of registration duties on credit operations by:
- Extending the exemption to deeds evidencing credit operations granted by all credit institutions and similar bodies
- Generalising the application of the fixed duty of 200 dirhams to deeds of suretyship, mortgage creation and pledging of business goodwill provided as security for credit operations
These provisions apply to deeds and agreements registered from 1 January 2026.
3. 0.1% Registration Duty on Public Contracts
The 2026 Finance Law broadened the registration obligation to include deeds and agreements for the performance of works, supplies or services on behalf of the State, local authorities and public establishments. Registration duties are applied at a rate of 0.1% to public contracts. These provisions apply to deeds and agreements registered from 1 January 2026.
4. Tax Incentive Regime for Corporate Group Restructuring
The 2026 Finance Law improved the tax incentive regime for corporate group restructuring operations by introducing:
- Exemption from registration duties on assumption of liabilities during the transfer of assets
- Application of a fixed duty of 1,000 dirhams to transactions involving the transfer of current assets between group companies
These provisions apply to deeds and agreements registered from 1 January 2026.
5. Reduction of Registration Duties on Share and Equity Interest Transfers
The 2026 Finance Law reduced the registration duty rate from 6% to 5% for transfers, whether for consideration or free of charge, of shares or equity interests in transparent real estate companies and predominantly real estate companies. In addition, a certificate of non-predominance in real estate must be presented to benefit from the exemption from registration duties on share and equity interest transfers. These provisions apply from 1 January 2026.
6. Exemption for Social Welfare Foundations of Public Administrations
The 2026 Finance Law established an exemption from registration duties for deeds of property acquisition by social welfare foundations of public administrations created by law, excluding deeds of property acquisition allocated to real estate transactions. This measure applies from 1 January 2026.
V – Measures Common to Income Tax and Corporate Income Tax
1. Withholding Tax on Rental Income from Immovable Property
The 2026 Finance Law broadened the scope of withholding tax to include rental income from built and unbuilt immovable property and constructions of all types. The withholding applies at a rate of 5% on the amount of rental income excluding VAT, with the right to offset against corporate income tax or income tax due.
For rents paid to legal entities: The withholding tax must be applied from 1 July 2026 by the State, local authorities, public establishments and enterprises and their subsidiaries, credit institutions and similar bodies, and insurance and reinsurance companies.
On a transitional basis, the withholding will also be applied by companies on a progressive basis:
- From 1 July 2026: companies with turnover excluding VAT ≥ 500 million MAD
- From 1 January 2027: companies with turnover excluding VAT ≥ 350 million MAD
- From 1 January 2028: companies with turnover excluding VAT ≥ 200 million MAD
For rents paid to individuals (under the actual net income or simplified net income regime): the withholding must be applied from 1 July 2026 by public or private legal entities and individuals whose income is determined under the actual net income or simplified net income regime.
2. Clarification of the Tax Treatment of Distributions by OPCC
The 2026 Finance Law clarified that amounts distributed by Collective Investment Schemes in Capital (OPCC) from profits corresponding to capital gains realised and interest received by said bodies are not considered as income from shares, equity interests and similar income. Capital gains and interest distributed by OPCC are subject to corporate income tax or income tax under the standard rules.
VI – Measure Common to Corporate Income Tax and VAT
Broadening of Withholding Tax to Remuneration for Services Rendered by Legal Entities
Regarding corporate income tax: the 2026 Finance Law broadened the scope of withholding tax on fees, commissions, brokerage and other remuneration of the same nature collected on behalf of the Treasury, to include remuneration for services rendered by legal entities. This withholding applies at a rate of 5% excluding VAT, with the right to offset against corporate income tax due.
The withholding will be applied on a progressive basis according to turnover:
- From 1 July 2026: companies with turnover excluding VAT ≥ 500 million MAD
- From 1 January 2027: companies with turnover excluding VAT ≥ 350 million MAD
- From 1 January 2028: companies with turnover excluding VAT ≥ 200 million MAD
Regarding VAT: the withholding tax is applied at 75% of the VAT amount on services whose list is set by regulation. In the absence of a certificate attesting to tax compliance, the withholding tax is applied at 100% of the amount of this tax. The same progressive calendar applies.
VII – Other Common Measures
1. Tax Regime for Sports Companies
The 2026 Finance Law clarified and improved the tax regime for sports companies on several fronts:
Regarding corporate income tax:
- Clarification of the triggering event for the total corporate income tax exemption for five (5) consecutive fiscal years: it applies from the fiscal year in which the first taxable sale was made
- Cash or in-kind donations granted to sports companies are deductible up to a limit of twenty per cent (20%) of the donor’s net profit, without the deduction exceeding five million (5,000,000) dirhams per fiscal year
- The contribution by a sports association of its assets and liabilities to a sports company may be carried out at fair value, without any tax impact on the association’s taxable income
Regarding income tax:
- Application of flat-rate allowances on salary income paid to professional athletes, coaches, educators and technical staff:
- 90% for the year 2026
- 80% for the year 2027
- 70% for the year 2028
- 60% for the year 2029
Regarding VAT:
- Extension of the VAT exemption, without the right to deduction, granted to sports companies for the period from 1 January 2026 to 31 December 2030
2. Simplification of Electronic Address Requirements
The 2026 Finance Law simplifies the process for holding an electronic address, providing that taxpayers subject to applicable taxes, duties and levies must hold an electronic address of their choice, in order to enable notification by electronic means in accordance with applicable legislation and regulations.
3. Adaptation of Electronic Accounting Rules
The 2026 Finance Law amended the provisions of Article 145-I of the CGI, providing that taxpayers must keep their accounts in electronic format in accordance with applicable legislation and regulations. The reference to a regulatory text for setting the criteria for electronic accounting has been removed.
4. Harmonisation of Tax Provisions and Corporate Insolvency Proceedings
The 2026 Finance Law provides that any company requesting the opening of safeguard proceedings must, prior to filing its request with the court registry, file a declaration to that effect electronically with the tax authorities, as is the case for judicial restructuring or liquidation proceedings.
It is also provided that when judicial restructuring or liquidation proceedings are not initiated by the company, the latter must file electronically a declaration of the opening of said proceedings within thirty (30) days from the date of publication of the opening judgment in the Official Gazette.
5. Simplification of Audit Procedures for Individuals
The 2026 Finance Law simplified audit procedures for individuals by allowing the tax authorities to carry out, simultaneously, an accounting audit and a comprehensive review of the overall tax situation of the individuals concerned, under certain conditions.
6. Lifting of the Statute of Limitations in Case of Non-Compliance with Tax Benefits
The 2026 Finance Law enshrined the general legal principle relating to the lifting of the statute of limitations in case of non-compliance with eligibility conditions for tax benefits accompanied by guarantees. The tax authorities may reassess taxes, duties and levies due, as well as fines, penalties and surcharges thereon, even if the statute of limitations has expired.
7. Update of Dematerialised Stamp Duties
The 2026 Finance Law repealed the provisions relating to the 3% discount on stamp duty orders for the benefit of auxiliary distributors, following the dematerialisation of stamp duties.
VIII – Extension of the Social Solidarity Contribution (CSS)
The 2026 Finance Law extended the application of the Social Solidarity Contribution on profits and income for the years 2026, 2027 and 2028.
Scope of Application
This contribution applies to:
- Companies subject to corporate income tax under the actual net income regime whose annual taxable profit is equal to or greater than one million (1,000,000) dirhams
- Individuals subject to income tax under the actual net income regime whose annual taxable profit is equal to or greater than one million (1,000,000) dirhams
CSS Rate Schedule
| Amount of profit or income subject to the contribution (in dirhams) | Contribution rate |
|---|---|
| From one million to less than 5 million | 1.5% |
| From 5 million to less than 10 million | 2.5% |
| From 10 million to less than 40 million | 3.5% |
| 40 million and above | 5% |
Official source: Summary Note of Tax Measures of Finance Law No. 50-25 for Fiscal Year 2026 – General Directorate of Taxes (DGI)
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Frequently Asked Questions
What are the main tax measures of Morocco’s 2026 Finance Law?
The 2026 Finance Law introduces a permanent exemption from withholding tax on international maritime transport, an adapted corporate income tax rate for microfinance institutions, VAT reverse charge on industrial waste and metals, broadening of withholding tax on rental income and service fees, extension of the CSS for 2026-2028, and measures in favour of sports companies.
What is the Social Solidarity Contribution (CSS) rate schedule in 2026?
The CSS applies to companies and individuals whose annual taxable profit is equal to or greater than 1 million dirhams. The rates are: 1.5% from 1M to 5M MAD, 2.5% from 5M to 10M MAD, 3.5% from 10M to 40M MAD, and 5% above 40M MAD. It has been extended for the years 2026, 2027 and 2028.
When does the withholding tax on rental income come into effect?
The 5% withholding tax on rental income from immovable property comes into effect on 1 July 2026 for the State, public establishments, banks and insurance companies, and companies with turnover excluding VAT equal to or greater than 500 million MAD. It will be progressively extended to smaller companies in 2027 and 2028.
What VAT exemptions are introduced by the 2026 Finance Law?
The 2026 Finance Law introduces VAT exemptions on short-cut pasta, uncooked and unfilled (without the right to deduction), blood and its derivatives (with the right to deduction), fertilisers and growing media for agricultural use, and a temporary exemption on the importation of live domestic bovine and camelid animals for the year 2026.
How does the 2026 Finance Law affect sports companies?
Sports companies benefit from the clarification of the total corporate income tax exemption for 5 fiscal years, deductibility of donations received (up to 20% of net profit, capped at 5M MAD), extension of the VAT exemption until 31 December 2030, and decreasing flat-rate allowances on salaries of professional athletes (90% in 2026, 80% in 2027, 70% in 2028, 60% in 2029).