On 28 November 2019, the Moroccan Council of Ministers approved the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI), which Morocco signed on 25 June 2019. After the internal ratification process is completed, Morocco must deposit its ratification instrument to bring the MLI into force for its covered agreements (tax treaties).
The MLI will generally enter into force for a particular covered agreement on the first day of the month following a three-month period after both parties to the covered agreement have deposited their ratification instrument. Once in force, the provisions of the MLI will generally apply for a covered agreement from 1 January of the year following its entry into force in respect of withholding taxes, and for all other taxes with respect to taxable periods beginning on or after the expiration of a 6-month period following the date of entry into force. However, solely for purposes of Morocco's own application of the MLI for other taxes, Morocco has opted for the MLI to apply from 1 January of the calendar year beginning on or after the expiration of the 6-month period.
Click the following link for Morocco's provisional list of reservations and notifications at the time of signature. A definitive list will be provided when the ratification instrument is deposited.
In addition to the BEPS MLI, the Council also approved the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports (CbC MCAA), which was also signed on 25 June 2019. Morocco is in the process of implementing CbC reporting requirements that are to apply from 2020 for MNE groups meeting an annual group revenue threshold of MAD 8.125 billion in the previous year.
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