Introduction: A Deeply Reformed Regime
The Withholding Tax (WHT) on dividends — income from shares, company interests and similar revenues — was profoundly overhauled by the Finance Law 2023 reforms and then simplified by Finance Law 2025. This guide summarizes the rules in force for distributions made from January 1, 2026.
1. Standard WHT Rate in 2026
In line with the tax convergence trajectory set by Finance Law 2023, the standard rate applicable in 2026 is:
> WHT Rate 2026: 11.25%
Key Simplification by Finance Law 2025
Finance Law 2025 abolished the FIFO rule (first in, first out) that distinguished profits by their year of origin. From 2026 onwards:
- The 11.25% rate applies to all distributed amounts from January 1, 2026, regardless of the fiscal year of the profits (including pre-2023 accumulated earnings).
- The maintenance of the 15% rate for old profits has been abolished.
- The passage to the final target rate of 10% is scheduled for distributions from January 1, 2027.
2. Treatment of Residents
A. Individual Residents (Natural Persons)
| Parameter | Value |
| WHT Rate | 11.25% |
|---|---|
| Nature | Liberatory of Income Tax (IR) |
The withheld tax is liberatory: the taxpayer does not need to include these dividends in their annual IR return.
B. Corporate Residents (Companies)
Principle: WHT ExemptionTo benefit from the exemption, the receiving company must provide a certificate of title ownership including its Tax Identification Number (IF) to the distributing company.
Accounting treatment of dividends received:| Mechanism | Detail |
| Integration | Dividends are included in the company's financial income |
|---|---|
| Allowance | 100% → total fiscal neutrality |
| Objective | Prevent cascading double taxation (IS already paid by the subsidiary) |
C. OPCI (Real Estate Collective Investment Organizations)
OPCIs receive a specific, derogatory treatment:
OPCI — Individual Shareholders
| Parameter | Value |
| WHT Rate | 15% (specific rate, above standard law) |
|---|---|
| Nature | Liberatory |
OPCI — Corporate Shareholders
| Situation | Applicable allowance |
| Dividends from rental income of an OPCI open to public ≥ 40% | 40% |
|---|---|
| All other cases | 0% (the 100% allowance is abolished for OPCIs) |
3. Treatment of Non-Residents
A. Standard Law Regime
WHT Rate: 11.25% — subject to tax conventions.> Primacy of Non-Double Taxation Conventions (NDTC): The 11.25% rate applies subject to the provisions of bilateral tax treaties concluded by Morocco. These treaties may provide for lower rates or exemptions depending on the beneficiary's residence.
B. Industrial Acceleration Zone (ZAI) and CFC Companies
Dividends from foreign sources distributed to non-residents:| Source of profits | WHT treatment |
| Profits from foreign sources (activities outside Morocco) | Total exemption |
|---|---|
| Profits from Moroccan sources (local activities) | 11.25% (subject to convention) |
4. Specific Exemptions and Preferential Regimes
| Entity / Regime | Treatment |
| FIFA (representations in Morocco, affiliated organizations) | Permanent exemption from WHT on dividends paid to FIFA |
|---|---|
| OPCVM (Collective Investment Organizations in Transferable Securities) | Exempt from WHT on dividends received |
| OPCR (Venture Capital Investment Organizations) | Exempt from WHT on dividends received |
| Foreign banks | Dividends distributed to shareholders exempt from WHT |
| Foreign holdings | Dividends distributed (proportional to offshore revenue) exempt from WHT |
| Foreign companies (securities disposals) | Capital gains exempt except real estate-dominant companies |
5. Obligations and Collection Procedures
Who is responsible?
WHT must be applied by:
- The distributing company (primary legal debtor)
- Or the delegated banking institution for dividend payment
Triggering event
The tax is due upon:
- Collection of income by the beneficiary
- Availability of funds
- Account credit of income in favor of the beneficiary
Payment deadline to the Treasury
The withheld amount must be paid to the Treasury within the month following that of the payment or account credit.
Penalties for non-compliance
| Breach | Penalty |
| Failure to withhold or remit | 10% fine on the amount not withheld |
|---|---|
| Late payment | 6% penalty for the 1st month + 1% per additional month |
6. WHT Rate Trajectory (2023–2027)
| Distribution year | Applicable WHT rate |
| 2023 | 13.75% |
|---|---|
| 2024 | 13.75% |
| 2025 | 13.75% (with FIFO rule simplification by FL 2025) |
| 2026 | 11.25% (single rate, all sources) |
| 2027 (planned) | 10% (final target rate) |
Summary Table — Morocco Dividend WHT 2026
| Beneficiary category | WHT Rate 2026 | Nature |
| Resident individual | 11.25% | Liberatory IR |
|---|---|---|
| Resident company (with IF certificate) | 0% (exempt) | 100% IS allowance |
| OPCI — individual shareholder | 15% | Liberatory IR |
| OPCI — corporate shareholder (open ≥ 40%) | Standard IS rate | 40% allowance |
| OPCI — corporate shareholder (other cases) | Standard IS rate | 0% allowance |
| Non-resident (standard law) | 11.25% | Subject to convention |
| ZAI/CFC — foreign source dividends to non-resident | 0% | Total exemption |
| ZAI/CFC — Moroccan source dividends to non-resident | 11.25% | Subject to convention |
| FIFA / OPCVM / OPCR / Offshore banks | 0% | Specific exemption |
Expert Advice from Accounting Services SARL
Managing dividend taxation requires particular vigilance: selecting the correct rate, providing IF certificates for companies, verifying tax treaties for non-residents, and meeting payment deadlines...
Our experts assist you with:
- Analysis of your situation (residency, shareholder type, profit source)
- Verification of eligibility under NDTC conventions
- Preparation of title ownership certificates
- Compliance with filing obligations and Treasury payment deadlines
- Optimization of the distribution structure within the legal framework
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