Morocco published a Decree No. 2.16.571 of 3 July 2017 in the Official Gazette No. 6594 on August 10, 2017 that describes the procedure for concluding advance pricing agreements (APAs). This decree was published in Arabic language. For example, a taxpayer who is resident in Morocco and has direct or indirect relationships with legal entities located outside of Morocco may draw an APA with the tax authority under this decree. Note that, here both unilateral and bilateral APAs are available.
According to this decree, the APA process adopted by satisfying four steps such as pre-filing, formal submission, review and negotiation, and lastly implementation and compliance. Taxpayers may participate in an introductory meeting with the Moroccan tax authority before a formal request for an APA is submitted, Taxpayers need to send to the Moroccan tax authority a formal request for an APA at least six months before the beginning of the first year the APA is predicted to cover. The APA will cover a period of up to four years.
Morocco is a signatory to tax treaties with more than 60 countries, including Belgium, China, Germany, Italy, Luxembourg, the Netherlands, Spain, the UK and the US, all of which contain the MAP provision for the purposes of negotiating bilateral, or multilateral APAs.
