At a glance
#Dates are for an example year end of Dec 31, 2025. Where local law moves a deadline on a weekend or national public holiday to the next working day, the date shown is already moved. Use the Deadlines tool for your own year end and thresholds.
Verified 2026-10-27. Tax authority: Direction Générale des Impôts (DGI). Summaries are simplified; check the linked official source before relying on them.
The law
#Article 213-II of the Code Général des Impôts (CGI) says that profits moved to a related company, by higher or lower buying or selling prices or any other means, are added back to the taxable result or turnover. The related company can be in Morocco or abroad. The tax office finds the profit by comparing with similar companies or by direct assessment on the information it holds. The text does not use the words arm's length. Article 214-III sets the documentation rules, and article 210 says when the file must be ready. Law 80-18 (Finance Law 2019) added the documentation duty and Law 65-20 (Finance Law 2021) added the master and local file split. Decree 2-22-1020 of 27 November 2025 sets the content of both files. The Arabic version was published in Bulletin Officiel 7464 of 11 December 2025 and the official French translation in Bulletin Officiel 7480 of 5 February 2026.
Documentation
#A company that has dealings with related companies abroad must give the tax office a master file and a local file, by electronic means, if its turnover excluding VAT is MAD 50m or more, or its gross assets are MAD 50m or more (art. 214-III-A). The files must be available when an accounting audit begins (art. 210). If they are missing during an audit, the tax office sends a request and the company has 30 days from receipt to hand them over. The same 30 days apply to a request for details about a foreign related party (art. 214-III-B). Decree 2-22-1020 lists the content. The master file has five parts and the local file has three. The local file must cover each type of controlled transaction that reaches MAD 1m excluding tax, with no netting of income and costs. Files may be in Arabic, French or English. There is no fixed yearly filing date and no separate transfer pricing form.
Methods
#The CGI names no methods. Article 213-II allows comparison with similar companies or direct assessment. The decree asks the local file to name the most appropriate transfer pricing method for each type of transaction and to explain the choice, with a comparability analysis. Advisers say the OECD methods are accepted. Advance pricing agreements are open under article 234 bis (Finance Law 2015) for up to four years, and the procedure is in the CGI annexes.
Penalties
#A company that does not produce the missing documents after the request is fined 0.5% of the value of the transactions covered, with a minimum of MAD 200,000 for each year concerned (art. 185-IV). If the files are missing or incomplete, the tie of dependence between the companies is presumed (art. 214-III-C). A missing country-by-country report, after a 15 day reminder, costs MAD 500,000 (art. 199 bis). A late corporate return carries a 5% surcharge up to 30 days late and 15% after that, and 20% where the tax office assesses the tax itself (art. 184). Records must be kept for 10 years (art. 185 bis).
Pillar Two
#Morocco has not enacted Pillar Two rules and no deadline applies. The 2026 CGI and Finance Law 50-25 contain no minimum top-up tax. The draft Finance Law 2027 (bill 60-26, sent to Parliament in October 2026) was also checked and has no GloBE or top-up tax rules. Deloitte's Morocco highlights (January 2026) say Morocco has not yet enforced the GloBE rules.
Other rules
#The corporate tax return is due within three months of the year end (art. 20-I), so 31 March for a 31 December year end. No extension was found in the CGI. Tax is paid in four instalments during the year and the balance is settled after year end. Article 163-I says a deadline that expires on a public holiday or legal non-working day moves to the next working day. Sunday is the weekly rest day. The tool moves deadlines off Sundays and holidays but not off Saturdays, because the CGI does not say Saturday is a legal non-working day. Moroccan holidays include 1 January, 11 January, 14 January (Amazigh New Year), 1 May, 30 July, 14 August, 20 August, 21 August, 31 October (Unity Day, from 2026), 6 November, 18 November, and the moon-based Eid al-Fitr, Eid al-Adha, Islamic New Year and Mawlid days. Companies pay corporate income tax at 20%, or 35% where net profit is MAD 100m or more, and 40% for banks and insurers (art. 19-I).
Filings and deadlines
#| # | Filing | When | Who | Source |
|---|---|---|---|---|
| 1 | Corporate income tax return (déclaration du résultat fiscal) Due within three months after the close of each accounting year (CGI art. 20-I), so 31 March for a 31 December year end. It is sent through the DGI online portal. Where the date falls on a public holiday, CGI art. 163-I moves it to the next working day (the tool also moves it off a Sunday). Late filing costs a 5% surcharge up to 30 days late and 15% after that (art. 184). No extension was found. | 3 months after year end (e.g. Mar 31, 2026) | Every company, taxable or exempt, except non-resident companies covered by art. 20-II and III. A nil or loss return must include a statement explaining the loss (art. 20-IV). | Code Général des Impôts 2026, art. 20-I and 163-I (DGI text, French; mirror copy) |
| 2 | Country-by-country report (déclaration pays par pays) Due within 12 months after the end of the accounting year, electronically (CGI art. 154 ter-I). The MAD 8,122,500,000 test applies to the year before the reported year. There is no general notification. A Moroccan company named as filer for the group must tell the DGI in advance (art. 154 ter-II and IV); DGI guidance as reported by Regfollower (September 2023) puts that notice at the last day of the reporting year. A DGI notice of 16 December 2022 temporarily excused companies under art. 154 ter-II (first and second indents) and III, but not a company named as filer; it was not found lifted. A missing report costs MAD 500,000 after a 15 day reminder (art. 199 bis). Where the date falls on a public holiday, CGI art. 163-I moves it to the next working day (the tool also moves it off a Sunday). | 12 months after year end (e.g. Dec 31, 2026) | A Moroccan company that is the ultimate parent of a group with consolidated turnover of MAD 8,122,500,000 or more in the prior year (art. 154 ter-I). Others file if the parent is in a country with no CbC filing or no information exchange with Morocco, or the group names them as filer (art. 154 ter-II). Art. 154 ter-III applies if the DGI tells them the exchange has failed. | Code Général des Impôts 2026, arts. 154 ter, 163-I and 199 bis (DGI text; mirror copy) |
| 3 | Local file (on tax office request or audit start) No yearly filing date. The file must be available when an accounting audit starts (CGI art. 210). If it is missing, the tax office sends a request and the company has 30 days from receipt to hand it over (art. 214-III-A). It is handed over electronically, in Arabic, French or English (Decree 2-22-1020 arts. 5 and 6). It must cover each type of controlled transaction of MAD 1m or more excluding tax. If it is not produced, the fine is 0.5% of the transactions covered, at least MAD 200,000 per year (art. 185-IV). | Within 30 days of a tax authority request | Companies that deal with related companies abroad and have turnover excluding VAT of MAD 50m or more, or gross assets of MAD 50m or more (the tool tests turnover only). | Code Général des Impôts 2026, arts. 210, 214-III-A and 185-IV (DGI text; mirror copy); Decree 2-22-1020 is in Bulletin Officiel 7480 |
| 4 | Master file (on tax office request or audit start) Same timing as the local file: available at the start of an accounting audit, and 30 days from receipt of a request if missing (CGI arts. 210 and 214-III-A). It has five parts: organisation chart, description of the group's business, intangibles, intragroup financing, and financial and tax position (Decree 2-22-1020 art. 3). Same fine as the local file. | Within 30 days of a tax authority request | Same test as the local file: turnover excluding VAT of MAD 50m or more, or gross assets of MAD 50m or more, and dealings with related companies abroad. | Code Général des Impôts 2026, arts. 210, 214-III-A and 185-IV (DGI text; mirror copy); Decree 2-22-1020 is in Bulletin Officiel 7480 |
Official texts
#- Code Général des Impôts 2026 (DGI edition, French; mirror copy), arts. 20, 154 ter, 163, 185, 199 bis, 210, 213, 214 and 234 bis (Law 2-00 on Copyright and Related Rights (as amended by Law 34-05), art. 8(a), says protection does not extend to official texts of a legislative, administrative or judicial nature, nor to their official translations.)