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Morocco has strategically positioned itself as a gateway to Africa, leveraging political stability, geographic proximity to Europe, and business-friendly tax regimes such as Casablanca Finance City (CFC) and industrial acceleration zones. However, the evolving international tax landscape is prompting a recalibration of Morocco’s tax offering to multinational enterprises (MNEs).
The OECD/G20’s BEPS 2.0 initiative, with its focus on Pillar One and Pillar Two, introduces significant challenges and opportunities. Pillar Two’s 15% global minimum tax, targeting large MNEs with consolidated revenues above €750 million, directly impacts Morocco’s preferential regimes, some of which offer effective tax rates below this threshold. MNEs with Moroccan subsidiaries or regional headquarters in CFC are increasingly scrutinizing their global effective tax rates (ETRs), and the risk of top-up taxation in other jurisdictions may undermine the appeal of local incentives.
In response, Moroccan policymakers are rethinking the structure of tax incentives. Finance Law 2024 began addressing this by refining the eligibility criteria for certain regimes and emphasizing substance-based benefits. The government is exploring mechanisms such as Qualified Domestic Minimum Top-up Taxes (QDMTTs) and refundable tax credits to preserve competitiveness while maintaining alignment with OECD standards.
At the same time, tax transparency and compliance expectations are rising. Morocco has already implemented country-by-country reporting (CbCR), enhanced transfer pricing documentation, and automatic exchange of financial information under the Common Reporting Standard (CRS). These measures, while increasing the administrative burden, also strengthen Morocco’s reputation as a responsible and compliant jurisdiction, an important factor for international investors and financial institutions.
For MNEs using Morocco as a platform to access Francophone Africa, this means reassessing tax structures, optimizing substance, and adapting to local reporting requirements. Casablanca Finance City, in particular, is at a crossroads. As a flagship initiative, it must evolve from offering pure tax advantages to emphasizing its ecosystem, infrastructure, and regional connectivity.
Additionally, emerging discussions around digital taxation and green tax policies may further influence Morocco’s fiscal landscape. Though the country has not yet adopted a digital services tax, it is closely monitoring international consensus under Pillar One to secure taxing rights from digital activity.
Conclusion
Global tax reforms are forcing Morocco to strike a delicate balance between international compliance and regional competitiveness. As it continues to align with OECD frameworks, its long-term success as a gateway to Africa will depend on offering not just favorable tax rates, but a transparent, stable, and substance-driven business environment. For MNEs, the opportunity remains, provided they evolve alongside Morocco’s changing tax ecosystem.
Reference/Citation
OECD (2021).
Statement on a Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy.
https://www.oecd.org/tax/beps/statement-on-a-two-pillar-solution-july-2021.htm
OECD (2022).
Global Anti-Base Erosion Model Rules (Pillar Two) – Inclusive Framework on BEPS.
https://www.oecd.org/tax/beps/inclusive-framework-on-beps.htm
Ministry of Economy and Finance – Kingdom of Morocco (2023).
Finance Law 2024 – General Presentation Note.
https://www.finances.gov.mahttps://www.finances.gov.ma
Casablanca Finance City Authority (2023).
Strategic Insights and Regulatory Developments.
https://www.casablancafinancecity.com
OECD (2023).
Tax Policy Reforms 2023: OECD and Selected Partner Economies.
https://www.oecd.org/tax/tax-policy-reforms-26173433.htm
World Bank (2022).
Doing Business in Morocco 2022: Investment Climate Assessment.
International Monetary Fund (IMF) (2022).
Morocco – Article IV Consultation Staff Report.
