Key takeaways: Between 2020 and 2026, seven successive Finance Laws (NC 730 to NC 737) profoundly reshaped the Moroccan tax system. Proportional corporate income tax (CIT), extension of the SSC (2026-2028), VAT harmonization, mandatory electronic invoicing: each year brought its share of structural reforms. This article traces, year by year, the major developments to provide business leaders and chartered accountants with a consolidated overview of the path traveled.
Why Understanding the Tax Reform Timeline Matters
Since 2020, Morocco has undertaken a deep overhaul of its tax system, in application of Framework Law No. 69-19 adopted in 2021. The 2019 National Tax Conference set the course: broadening the tax base, simplifying rates, ensuring tax neutrality for restructuring operations, and digitalizing filing obligations.
Each Finance Law (FL) constitutes a building block of this transformation. Understanding their sequence is essential to anticipate upcoming obligations and optimize your company’s tax strategy.
Summary Table of 2020-2026 Reforms
| Year | Circular Note | Key Measures |
|---|---|---|
| 2020 | NC 730 | CIT convergence initiated, minimum contribution lowered to 0.50% (the 0.75% rate dated from FL 2019) |
| 2021 | NC 731 | SSC reintroduced, tax neutrality for restructurings (Art. 247-XXVIII) |
| 2022 | NC 732 | Elimination of progressive CIT, fiscal group concept |
| 2023 | NC 733 | Major reform: Proportional CIT 20%/35%/40%, 2023-2026 transition, minimum contribution 0.25% |
| 2024 | NC 735 | 13.75% withholding tax on dividends (transitional step), registration fee exemption for company formation |
| 2025 | NC 736 | Legal framework for electronic invoicing, monthly CNSS |
| 2026 | NC 737 | Target CIT rates reached, SSC extended 2026-2028, electronic invoicing mandatory for large companies |
2020 — NC 730: The Starting Point of Convergence
The 2020 Finance Law marked the beginning of the progressive convergence of CIT toward a proportional system. The multiple rates applied according to profit brackets began to be rationalized.
Minimum Contribution Lowered to 0.50%
The increase of the minimum contribution to 0.75% of turnover dated from FL 2019; the 2020 Finance Law instead lowered it to 0.50% for profitable companies, beginning to ease the burden on profitable businesses while preserving CIT revenue.
2021 — NC 731: Consolidation and Restructuring Neutrality
The 2021 Finance Law extended the 2020 guidelines without major upheaval.
SSC Reintroduced
The Social Solidarity Contribution was reintroduced by FL 2021 as a levy on the profits of companies whose taxable income exceeds a certain threshold. Presented as temporary, it was subsequently renewed and extended over successive fiscal years.
Tax Neutrality for Restructurings (Art. 247-XXVIII)
Merger, demerger, and partial asset contribution operations benefited from a reinforced tax neutrality regime. Capital gains recorded during these operations can be neutralized under certain conditions, encouraging companies to restructure without immediate tax cost.
2022 — NC 732: Elimination of Progressivity and Fiscal Groups
Abandonment of the Progressive CIT Scale
The 2022 Finance Law eliminated the progressive scale system for CIT in favor of a single proportional rate applicable to the entire profit. This measure considerably simplified the tax calculation for businesses.
Introduction of the Fiscal Group Concept
The legislator laid the foundations for group taxation, allowing holding companies and subsidiaries to consolidate certain aspects of their taxation. Although limited in its first version, this concept paved the way for legitimate tax optimization within Moroccan corporate groups.
2023 — NC 733: The Major Reform
The year 2023 marks the decisive turning point of the Moroccan fiscal decade. The 2023 Finance Law implemented the most structuring recommendations of Framework Law No. 69-19.
Proportional CIT: 20%, 35%, and 40%
The proportional system was established with three rates:
- 20%: standard rate for companies whose net taxable profit does not exceed 100 million dirhams
- 35%: for companies whose profit exceeds 100 million dirhams
- 40%: reserved for credit institutions, Bank Al-Maghrib, CDG, and insurance companies
A 2023-2026 transition period was planned to progressively reach these target rates.
Minimum Contribution Lowered to 0.25%
For profitable companies, the minimum contribution was reduced to 0.25%, a strong signal to ease the tax burden on profitable businesses and encourage accounting transparency.
Preparing the VAT Reform
It was the 2024 Finance Law that engaged VAT harmonization around two rates (10% and 20%), under a progressive calendar completed by the 2026 Finance Law. The objective: eliminate unjustified exemptions and reduce the VAT credit backlog.
Income Tax Scale Adjustment
The income tax scale was restructured with a higher exemption threshold and adjusted intermediate brackets to better account for inflation.
2024 — NC 735: Dividends and Registration Fees
Withholding Tax on Dividends: 13.75% Step
The 2024 Finance Law set the transitional rate of 13.75% for withholding tax on distributed dividends. This rate is part of a convergence trajectory in annual steps (13.75% in 2024, 12.5% in 2025, 11.25% in 2026, 10% from 2027). The applicable rate is the one in force in the year the dividends are paid out, regardless of the fiscal year in which the distributed profits originated.
Registration Fee Exemption for Company Formation
A flagship measure for business creators: company formation deeds are now exempt from registration fees. This exemption significantly reduces creation costs and strengthens Morocco’s attractiveness for entrepreneurship.
2025 — NC 736: Digitalization and Monthly CNSS
Legal Framework for Electronic Invoicing
The 2025 Finance Law established the legal framework for electronic invoicing in Morocco. The implementing texts define technical standards, approved platforms, and the progressive rollout calendar.
CNSS: Switch to Monthly Filing
A major change for payroll management: CNSS filing shifted from a quarterly to monthly basis starting in 2025. This measure directly impacts the work of chartered accountants who must adapt their payroll and filing processes.
2026 — NC 737: Culmination of Reforms
The 2026 Finance Law marks the culmination of the trajectory initiated in 2023.
Target CIT Rates Reached
The transition rates are complete: the 20% rate fully applies to standard companies and the 35% rate to large enterprises. The system is now stabilized.
Extension of the SSC (2026-2028)
The Social Solidarity Contribution is extended for fiscal years 2026 to 2028 by the 2026 Finance Law. It remains due by companies whose net profit is equal to or above 1 million dirhams, under a progressive scale: 1.5% (1 to 5M), 2.5% (5 to 10M), 3.5% (10 to 40M) and 5% (40M and above). The companies concerned must therefore continue to calculate and declare it.
Mandatory Electronic Invoicing for Large Companies
Companies with turnover exceeding the threshold set by decree must issue and receive invoices in standardized electronic format. SMEs will follow according to the planned progressive calendar.
Frequently Asked Questions
What is the difference between NC 730 and NC 733?
NC 730 (2020) initiated CIT convergence without fundamentally altering its structure. NC 733 (2023) carried out the major reform by establishing proportional CIT at three rates (20%, 35%, 40%) and launching a four-year transition. It is truly NC 733 that redesigned the Moroccan tax landscape.
Is the SSC abolished in 2026?
No. The 2026 Finance Law (NC 737) actually extends the Social Solidarity Contribution for fiscal years 2026 to 2028. Companies whose net profit reaches or exceeds 1 million dirhams remain liable for this levy, calculated under a progressive scale ranging from 1.5% to 5% of net profit. Declarations remain subject to the rules in force at the closing of each fiscal year.
How can a chartered accountant help me navigate these reforms?
The chartered accountant is the best-placed professional to anticipate the impact of each reform on your business: calculating CIT under the new rates, adapting electronic invoicing processes, transitioning to monthly CNSS, and optimizing registration fees. They provide ongoing monitoring and adapt your tax strategy in real time.
Need Tailored Support?
At Upsilon Consulting, we have been helping Moroccan businesses adapt to each tax reform since 2020. From CIT compliance to electronic invoicing preparation, our team of chartered accountants guides you every step of the way.
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