On 16 December 2022, the Moroccan tax authority published an announcement, which temporarily suspending the requirement to file a country-by-country (CbC) report for companies that are part of multinational enterprises (MNEs) operating in Morocco referred to articles 154 Ter II and article 154 Ter III of the Tax Code, i.e., companies that are part of MNEs whose ultimate parent entity (UPE) is located in a jurisdiction that does not require the filing of such CbC report and with which Morocco has not concluded an agreement allowing exchange of information for tax purposes or has concluded such an agreement but the tax authorities fail to exchange information.
The announcement reminds enterprises whose UPE or surrogate parent entity is a tax resident of Morocco of their requirement to e-file the CbC report for fiscal year 2021 by the 31 December 2022 deadline.
Until a notice from the tax authority, no filing of CbC reports is expected from Moroccan subsidiaries of MNEs unless such subsidiaries are appointed as a surrogate parent entity.
