Morocco's 2027 Draft Finance Bill: the key business tax measures

Korte Law advises development agencies, international organisations, embassies and the companies that work with them in Morocco. We help them contract with Moroccan public bodies, run donor-funded programmes under the right procurement rules, work with local partners, and employ local staff correctly.

What We Cover

• Contracts with Moroccan ministries, local authorities and public establishments under the public procurement decree
• Donor-funded contracts: when the procurement rules of an international agreement apply instead of the Moroccan decree, and how to document that
• Tender files, bids and contract review for contractors and consultants on donor-funded projects
• Grant, implementation and partnership agreements with Moroccan associations, cooperatives and companies
• Setting up a local presence: project office, branch, company or association, and its registrations
• Local employment: contracts for local staff, consultants and drivers, CNSS registration, terminations, and contracting licensed guarding companies
• Personal data of staff, beneficiaries and suppliers: CNDP declarations and transfers abroad
• Public-private partnerships and infrastructure contracts

The Legal Framework

Public purchasing is governed by Decree 2-22-431 of 8 March 2023 on public procurement, which replaced Decree 2-12-349 of 2013 and covers the State, local authorities and public establishments. The decree allows a derogation for contracts awarded under agreements that Morocco has concluded with international organisations or foreign states, where the agreement expressly provides for particular procurement procedures. Public-private partnerships fall under a separate regime: Law 86-12, as amended by Law 46-18 of 2020.

Associations are governed by the Dahir of 15 November 1958 on the right of association, as amended. An association that receives funding from abroad must declare the amount and its origin to the Secretariat General of the Government within 30 days (Article 32 bis). Personal data is protected by Law 09-08, which applies to any organisation established in Morocco or using processing means there, and normally requires a prior declaration to the CNDP.

Whether Moroccan labour and social security law applies to locally recruited staff of an embassy or an international organisation depends on its status and its agreement with Morocco. We check that first, before any contract is drafted.

How We Work

We work in English and French, to the timetable and reporting format of the programme. We know how a Moroccan public body reads a contract and how a donor's compliance team reads it, and we draft so that both can sign. For ongoing programmes we act as local counsel on call: contracts, staff questions and partner agreements, under one engagement.

Related Guides

• Public procurement in Morocco: a legal guide for bidders
• Infrastructure projects and PPP in Morocco
• Energy law in Morocco
• Labour law for international employers
• Data protection and privacy law in Morocco

A closing word on method. Work of this kind is carried out by lawyers on the ground in Morocco, because the outcome depends on local procedure and local practice as much as on the text of the law. That is the part an adviser outside the country cannot supply.

Speak to a lawyer about your project

A registered address in Rabat for your Moroccan company — 175 euros a month, with every letter received, scanned and in your inbox the same working day.

Our premises in Rabat — Villa 7, Rue Maa Al Ainine, Cité Administrative, Agdal Ouest.

The meeting room, available at the company's own address.

A Moroccan company needs a registered office from the day it is incorporated, and the address it gives the commercial register is the address the administration, the tax office and the courts will use. We provide that address at our own premises in Rabat, under a written domiciliation agreement, together with the mail handling that makes the address work in practice.

The service is used by international groups that are setting up a Moroccan subsidiary before they take their own lease, by companies whose activity does not require premises of their own, and by international law firms that need a reliable local address for a client's Moroccan entity.

What the service includes

A registered office at our premises in Rabat, named as the company's siège social in its articles and in the commercial register, under a domiciliation agreement that complies with Law 89-17.

Reception of all mail addressed to the company, including registered letters and deliveries from the administration.

A daily scan of every item received, forwarded to you by email the same working day, so nothing waits at a counter and nothing is opened without your knowledge.

Forwarding of the originals on request, and a meeting room at our offices when you need to receive a visitor, a notary or an auditor at the company's own address.

175 euros per month. No commission on filings, no charge per letter. The agreement runs month to month after the first year.

Changes to the commercial register

A company's entry in the commercial register has to follow the company. We prepare and file the modifications, with the minutes and the supporting documents that each one requires:

Transfer of the registered office, change of company name, change of corporate purpose.

Appointment, renewal or removal of a manager or of the members of the board.

Increase or reduction of the share capital, transfer of shares, change of shareholders.

Conversion from one form to another, for example a SARL becoming a SA, and the opening or closing of a branch.

Deregistration, and the publications in the legal gazette and the Official Bulletin that go with each of these steps.

Corporate work around the address

Domiciliation is rarely the whole need. We handle the company's corporate life alongside it: annual general meetings and minutes, statutory registers, the beneficial-ownership register, the filing of the accounts, powers of attorney, and the corrections that surface when a bank, a client or an auditor reads the file closely.

Where the company is being formed, the address and the incorporation are handled together, so the articles, the domiciliation agreement and the register entry say the same thing from the start.

What you need to provide

The company's articles or, for a company not yet formed, the negative certificate and the draft articles; identification of the manager and of the beneficial owners; and the signed domiciliation agreement. We prepare the agreement and the register filings.

Working language

We work in French, German and English, and file in French and Arabic as the administration requires.

A closing word on method. Work of this kind is carried out by lawyers on the ground in Morocco, because the outcome depends on local procedure and local practice as much as on the text of the law. That is the part an adviser outside the country cannot supply.

Tell us about your company

Foreign investment in Morocco concentrates in a handful of sectors, and each carries its own regulator, incentive regime and contract practice. We advise international companies in the sectors below with dedicated, regularly updated legal guides behind each entry — written by the lawyers who handle these matters in Rabat and Casablanca.

Where We Concentrate

• Automotive & Aerospace Suppliers — plant set-up, free zones, supply contracts, incentives
• Green Hydrogen and Renewable Energy & IPP — permitting, land, offtake, Law 13-09
• Hotels & Tourism — development, management agreements, the 2030 horizon
• Banking & Finance and Fintech — security packages, licensing, Bank Al-Maghrib practice
• Insurance — ACAPS regulation for foreign insurers, brokers and corporate buyers
• Technology, Cloud & AI and Engineering Nearshoring
• Infrastructure & PPP and Public Procurement for foreign contractors and bidders
• Mining — licences, the 2024–2026 reform, ESG

How Sector Work Runs

Sector mandates combine the corporate base — entity, contracts, employment, tax coordination — with the sector regulator's requirements and the incentive instruments of the Investment Charter. The guides linked above set out the framework per sector; in a mandate, the same lawyers apply it to your project.

A closing word on method. Work of this kind is carried out by lawyers on the ground in Morocco, because the outcome depends on local procedure and local practice as much as on the text of the law. That is the part an adviser outside the country cannot supply.

In Morocco, company secretarial services — secrétariat juridique, or corporate housekeeping — cover everything that keeps a company in good standing after formation: general meetings, minutes, statutory registers, filings with the commercial register and OMPIC, and the beneficial-ownership register. We provide this as a continuing service for foreign parent companies that own a Moroccan SARL, SA or SAS, and for international law firms that need a reliable corporate-compliance provider for a client's Moroccan subsidiary. The work runs remotely for the parent — in English, German or French, with your legal department as our counterpart — while signatures, registry filings and notarial steps are handled by us on site in Rabat and Casablanca.

What We Cover

• Annual approval of accounts and the ordinary general meeting, within six months of the financial year-end
• Statutory registers and minute books, including the certified share register and pre-numbered minute books
• Beneficial-ownership register (Registre des Bénéficiaires Effectifs): initial declarations and updates via OMPIC
• Filings with the Registre de Commerce and OMPIC formalities, including publication requirements
• Appointment and removal of gérants, directors and auditors, with the required majorities and filings
• Share transfers, capital increases and reductions, conversions of company form and amendments of articles
• Registered office changes and domiciliation arrangements under Law 89-17
• A corporate calendar with deadline monitoring for every entity under our care
• Coordination with your chartered accountant, the commissaire aux comptes and the Office des Changes
• A corporate health check of existing registers, minutes and filings at the start of every engagement

The Legal Framework

The annual cycle is prescribed by Law 5-96 for the SARL and Law 17-95 for the SA, as amended by Laws 21-19 and 19-20 — which now permit videoconference board meetings for the SA — together with the Commercial Code (Law 15-95), whose Title VIII, added by Law 89-17, governs domiciliation. The beneficial-ownership register was created under Law 12-18 and is managed electronically by OMPIC; Law 53-05 and Law 43-20 govern electronic signatures and trust services for documents that no longer need wet ink.

The deadlines carry real sanctions. A gérant who fails to file required documents with the court registry faces imprisonment of one to six months or a fine under Article 108 of Law 5-96, and directors of an SA face equivalent exposure under Law 17-95. Most compliance failures we see are not substantive breaches but missed deadlines, unsigned minutes and unfiled changes — exactly what a maintained corporate calendar prevents.

How We Work

Every engagement starts with a corporate health check: we review the entity's registers, filings, minutes, articles, beneficial-ownership declarations, OMPIC records and domiciliation status, and where something is missing we deliver a remediation plan with a clear timetable.

The entity then moves onto an annual retainer covering the full compliance cycle — meetings, minutes, registers, filings, the corporate calendar — with ad hoc corporate changes such as manager appointments, share transfers or capital measures handled at an agreed scope as they arise.

Drafting, review and approvals run electronically with the parent company; where Moroccan law requires physical presence — court registry filings, notarial acts, bank formalities, original certified registers — we act from our own offices in Rabat and Casablanca. For the full legal detail, see our guide on the annual corporate compliance cycle of a Moroccan subsidiary.

Related Articles

• Corporate Compliance for a Moroccan Subsidiary: Annual Cycle, Registers, Filings and Deadlines (2026)
• Company Formation in Morocco for Foreign Investors
• Private M&A in Morocco: Deal Structures, SPA Terms and Closing Mechanics
• Morocco Local Counsel for International Law Firms

A closing word on method. Work of this kind is carried out by lawyers on the ground in Morocco, because the outcome depends on local procedure and local practice as much as on the text of the law. That is the part an adviser outside the country cannot supply.

Speak to a lawyer about your project

Korte Law guides international companies through every step of entering the Moroccan market — from choosing the right legal structure to completing registration and obtaining the necessary authorizations. We are the preferred legal partner for European and international companies establishing and growing their business in Morocco.

What We Cover

• Choosing the right legal structure: SARL, SA, branch, liaison office, or joint venture
• Company incorporation at the Regional Investment Centre (CRI)
• Foreign investment notification and registration with Office des Changes
• Obtaining sector-specific licenses and regulatory approvals
• Shareholders' agreements and governance frameworks
• Local partner selection and joint venture structuring
• Free zone setup (CFC, Tanger Med, industrial free zones)
• Post-incorporation compliance: board resolutions, share transfers, capital increases

The Legal Framework

Foreign investment in Morocco is governed by the Investment Charter (Law 18-95, reformed 2022), which guarantees free transfer of profits and repatriation of capital for registered investments. The main corporate forms are the SARL (société à responsabilité limitée, minimum MAD 1 capital) and the SA (société anonyme, minimum MAD 300,000 capital, required for regulated activities and publicly listed companies). Company registration is processed through the CRI (Centre Régional d'Investissement), with a unified window that has significantly reduced setup timelines.

Branch offices of international companies are permitted but attract different tax treatment and may face restrictions in regulated sectors. Liaison offices are non-trading and cannot generate local revenue. Free zone entities benefit from IS exemption for the first 5 years and reduced rates thereafter.

How We Work

We handle the full setup process — from structure recommendation through to the first board meeting. We manage registration filings, draft all constitutional documents, advise on governance, and ensure the investment is properly registered with the Office des Changes to protect your right to repatriate returns. For complex or regulated entries, we coordinate with sector regulators and manage the full authorization timeline.

A closing word on method. Work of this kind is carried out by lawyers on the ground in Morocco, because the outcome depends on local procedure and local practice as much as on the text of the law. That is the part an adviser outside the country cannot supply.

Speak to a lawyer about your project

Korte Law advises international companies and investors on commercial contracts governed by Moroccan and German law. Whether you are entering a distribution agreement, a supply contract, or a joint venture, we ensure your contracts are enforceable and aligned with local legal requirements.

What We Cover

• Drafting and reviewing commercial contracts under Moroccan and German law
• Distribution, agency, and franchise agreements
• Joint venture and shareholders' agreements
• Supply chain and procurement contracts
• Service agreements and consulting contracts
• Contract renegotiation and variation
• Pre-contractual liability and heads of terms

The Legal Framework

Commercial contracts in Morocco are governed primarily by the Code des Obligations et Contrats (DOC, 1913) — Morocco's civil code — supplemented by the Code de Commerce (1996) for commercial relationships. For cross-border transactions, the choice of law clause and governing jurisdiction are critical: Moroccan courts will apply mandatory provisions of Moroccan law even when foreign law is chosen, particularly for contracts performed in Morocco.

For German-law contracts, we work within the BGB (Bürgerliches Gesetzbuch) and HGB (Handelsgesetzbuch), including the commercial agency provisions of §§ 84–92c HGB, which have extraterritorial implications for Moroccan agents of German principals.

How We Work

We take a practical, transaction-focused approach. We identify the key risk points in your contract structure, draft clear and enforceable clauses, and flag issues specific to Morocco — such as mandatory arbitration limitations, foreign currency payment restrictions, and enforceability of penalty clauses. We work in English, French, German, and Arabic, and our agreements are designed to hold up before Moroccan courts or international arbitration tribunals.

A closing word on method. Work of this kind is carried out by lawyers on the ground in Morocco, because the outcome depends on local procedure and local practice as much as on the text of the law. That is the part an adviser outside the country cannot supply.

Speak to a lawyer about your project

Korte Law advises investors, developers, lenders and industrial users on energy projects in Morocco, one of Africa's most active markets for renewable power. We support projects across their whole life: the choice of regime, licences and grid access, land, power purchase agreements, and financing.

What We Cover

• Renewable power projects under Law 13-09: declarations, authorisations and the choice of regime (solar, wind, hybrid, storage)
• Self-production of electricity under Law 82-21 and Decree 2-25-100: declaration, connection agreement or authorisation, and regularisation of existing plants
• Grid access and connection agreements with the transmission and distribution operators, and grid-use tariffs set by ANRE
• Power purchase agreements (PPAs) with industrial and commercial offtakers, EPC and O&M contracts
• Land for energy projects: purchase, lease and the allocation of public land
• Green hydrogen and Power-to-X projects under the "Offre Maroc" framework
• Energy programmes funded by development banks and international donors: contracting, procurement rules and local compliance
• Project finance, lender-side review and energy M&A

The Legal Framework

Renewable power generation is governed by Law 13-09 on renewable energies, amended by Law 58-15 (2016) and overhauled by Law 40-19 (Bulletin officiel no. 7270 of 1 February 2024), which also introduced storage and certificates of origin. Law 48-15 created the national electricity regulator, ANRE, which sets the tariffs for using the national transmission grid and the medium-voltage distribution grids.

Law 82-21 on self-production lets a business produce electricity for its own consumption. Its implementing decree, Decree 2-25-100 of 5 March 2026 (Bulletin officiel no. 7489), sets three regimes by plant capacity: a declaration, a connection agreement with the grid operator, or a ministerial authorisation. Up to 20% of annual output may be sold to the grid operator at a tariff set by ANRE. Under Law 47-09 on energy efficiency, large energy consumers must carry out periodic energy audits.

For green hydrogen, a Head of Government circular of March 2024, known as the "Offre Maroc", makes public land available to selected investors, with 300,000 hectares in a first phase. It is a circular, not a statute: land rights are secured by contract with the State.

How We Work

We start with the regime, because it decides the timetable: which file, which authority, which grid operator, and in which order. We then draft and negotiate the contracts that hold the project together, from land and grid connection to the PPA and the financing documents. We work alongside technical advisers, lenders' counsel and the authorities, and we act for donor-funded energy programmes as well as for private investors.

Related Guides

• Renewable energy and independent power production in Morocco
• Client alert: self-production of electricity is now workable
• Green hydrogen projects in Morocco: permitting, land and offtake
• Infrastructure projects and PPP in Morocco
• Public-sector and donor-funded work in Morocco

A closing word on method. Work of this kind is carried out by lawyers on the ground in Morocco, because the outcome depends on local procedure and local practice as much as on the text of the law. That is the part an adviser outside the country cannot supply.

Speak to a lawyer about your project

Korte Law advises international employers in Morocco: companies setting up their first team, groups with established subsidiaries, and embassies, international organisations and development programmes that employ local staff. We act for employers, from the first contract to the end of the relationship.

What We Cover

• Employment contracts: permanent (CDI) and fixed-term (CDD), trial periods, executive and senior management agreements
• International staff: the contract visa for non-Moroccan employees, filed through the labour ministry's TAECHIR platform, residence formalities and secondments
• CNSS registration of the employer and its staff, and social security compliance
• Disciplinary procedure, dismissals and severance calculations
• Internal regulations (règlement intérieur), HR policies and staff data under Law 09-08
• Guarding and security staff: contracting licensed guarding companies and allocating labour-law risk in the service contract
• Local staff of embassies, international organisations and donor-funded programmes: which law applies, contracts and terminations
• Independent contractors and consultants, and the risk of requalification as employees
• Labour disputes, negotiation with staff representatives and representation before the courts

The Legal Framework

Employment is governed by the Labour Code, Law 65-99, enacted by Dahir 1-03-194 of 11 September 2003 (Bulletin officiel no. 5210 of 6 May 2004).

Hiring a non-Moroccan employee requires an authorisation from the labour ministry, given as a visa on the employment contract; the visa date is the date the contract takes effect, and any change to the contract needs a new visa (Article 516). The contract follows the official model (Article 517) and must commit the employer to pay the employee's return journey if the visa is refused (Article 518). Applications are filed online through TAECHIR.

On a permanent contract the trial period is three months for managers, six weeks for employees and fifteen days for workers, renewable once (Article 14). Before a dismissal for misconduct the employee must be heard within eight days of the facts being established, assisted by a staff delegate or union representative of their choice (Article 62). After six months' service, severance runs at 96 to 240 hours of salary per year of service, depending on seniority (Articles 52-53).

Employers must register themselves and their staff with the CNSS under the Dahir of 27 July 1972. Private guarding and cash-transport companies are regulated by Law 27-06 (Dahir 1-07-155 of 30 November 2007).

How We Work

We set up the employment structure correctly from the start: the right contract, the visa file, CNSS registration and internal rules. That avoids the problems we see most often with international employers: workers who are treated as contractors but are in fact employees, contracts for non-Moroccan staff that were never stamped, and dismissals that fail on procedure. When a dispute arises, we represent the employer in negotiation and before the labour courts.

Related Guides

• Labour law in Morocco: compliance guide for employers
• Hiring expatriates in Morocco: work permits and payroll
• Hiring independent contractors in Morocco
• CNDP filings for employee data
• Public-sector and donor-funded work in Morocco

A closing word on method. Work of this kind is carried out by lawyers on the ground in Morocco, because the outcome depends on local procedure and local practice as much as on the text of the law. That is the part an adviser outside the country cannot supply.

Speak to a lawyer about your project

Korte Law advises clients on international arbitration involving Morocco and the MENA region. We assist with drafting dispute resolution clauses, managing arbitration proceedings, and enforcing foreign awards — combining knowledge of Moroccan arbitration law with experience in ICC and ad hoc proceedings.

What We Cover

• Drafting and reviewing arbitration clauses in commercial contracts
• Representing clients in ICC, CIMAC, and ad hoc arbitration proceedings
• Emergency arbitrator applications and interim measures
• Enforcement of foreign arbitral awards in Morocco
• Setting aside proceedings before Moroccan courts
• Expert witness coordination and document production
• Mediation and alternative dispute resolution
• Cross-border enforcement strategy in Germany and France

The Legal Framework

Arbitration in Morocco is governed by Law 08-05, which reformed the Code of Civil Procedure and introduced a modern framework for both domestic and international arbitration. Morocco is a signatory to the New York Convention (1958), enabling enforcement of foreign awards subject to limited public policy exceptions. The CIMAC (Centre International de Médiation et d'Arbitrage de Casablanca) is the primary local arbitration institution.

Moroccan courts have generally upheld international arbitration agreements and enforced foreign awards, although the process can take 12–18 months and requires proper authentication of award documents. For German-connected disputes, the DIS (Deutsche Institution für Schiedsgerichtsbarkeit) provides a well-established institutional framework.

How We Work

We approach dispute resolution strategically — advising on clause drafting before disputes arise, and representing clients assertively when they do. We understand the procedural and cultural dynamics of arbitration in Morocco and how Moroccan courts approach enforcement. Our multilingual team handles cases in English, French, German, and Arabic, and we work with co-counsel in other jurisdictions when cross-border enforcement is needed.

A closing word on method. Work of this kind is carried out by lawyers on the ground in Morocco, because the outcome depends on local procedure and local practice as much as on the text of the law. That is the part an adviser outside the country cannot supply.

Speak to a lawyer about your project

Korte Law advises foreign investors and multinationals on Moroccan tax law — covering corporate income tax, withholding taxes, transfer pricing, and the tax implications of investment structures. We combine Moroccan tax expertise with cross-border experience to optimize your tax position while ensuring compliance.

What We Cover

• Corporate income tax (IS) structuring and compliance advice
• Withholding tax on dividends, royalties, and service fees
• Tax treaty analysis (Morocco has DTAs with 50+ countries)
• Transfer pricing documentation and audit defense
• Free zone tax regimes (CFC, industrial free zones)
• VAT obligations for international companies operating in Morocco
• Tax due diligence for M&A transactions
• Investment Charter incentives and sectoral tax exemptions

The Legal Framework

Moroccan taxation is governed by the Code Général des Impôts (CGI), which consolidates corporate tax (IS at 20–35%), personal income tax (IR), VAT (TVA at 20%), and registration duties. Morocco's Investment Charter (Charte de l'Investissement, Law 18-95 and its 2022 reform) provides significant tax incentives for qualifying investments, including IS exemptions, reduced withholding rates, and customs duty relief.

Morocco has concluded double taxation agreements with more than 50 countries — including Germany, France, and key Gulf states — which are critical for structuring cross-border payments. Transfer pricing rules under Article 213 of the CGI follow OECD guidelines, with documentation requirements triggered at MAD 50 million in related-party transactions.

How We Work

We work at the intersection of legal structuring and tax planning. We are not a tax advisory firm — we provide legal analysis of tax obligations and structure transactions to minimize tax exposure within compliant frameworks. We work alongside your accountants and tax advisors, and coordinate with Moroccan tax authorities when rulings or clarifications are needed. When disputes arise, we support audit defense and administrative appeals.

A closing word on method. Work of this kind is carried out by lawyers on the ground in Morocco, because the outcome depends on local procedure and local practice as much as on the text of the law. That is the part an adviser outside the country cannot supply.

Speak to a lawyer about your project

Tax Compliance and Accounting Coordination

For foreign-owned Moroccan entities we also act as the single point of coordination for the recurring tax and accounting cycle: we align the corporate-law side — approvals, minutes, filings — with the work of established Moroccan chartered accountants and statutory auditors, review the legal dimension of tax positions, and keep your parent company’s legal and finance teams in one conversation in English, German or French. One counterpart instead of three.