Projet de Loi de Finances 2026 : les principales mesures fiscales adoptées en décembre 2025

THE Draft Finance Bill (PLF) 2026 It was definitively adopted by Parliament in December 2025, following its successive review by both chambers. Below is an overview of the main tax measures adopted:

1. Common and cross-cutting measures

1.1. Extension of withholding tax (corporate income tax and VAT) on services

The scope of withholding tax is extended to remuneration for services rendered by the following entities:

credit institutions and similar organizations,
insurance and reinsurance companies,
companies whose turnover reaches certain thresholds.

Implementation is gradual, depending on turnover:

starting from 1^er July 2026: companies with a turnover ≥ 500 million dirhams,
starting from 1^er January 2027: companies with a turnover ≥ 350 million dirhams,
starting from 1^er January 2028: companies with turnover ≥ 200 million dirhams.

1.2. Withholding tax on business rents

A withholding tax of 5 % is established on the rental income from built or unbuilt properties and constructions of any kind, when the rents are paid by certain taxpayers to:

companies subject to corporate income tax,
or natural persons subject to professional income tax (RNR/RNS scheme).

The measure applies from the 1^er July 2026. The amount withheld is deductible from the final tax due, with the possibility of a refund in case of excess.

1.3. Extension of the Social Solidarity Contribution (CSS)

The social solidarity contribution on profits and income is extended for the years 2026, 2027 and 2028. It remains payable by companies and natural persons under the actual net profit regime whose annual profit reaches or exceeds 1 million dirhams, according to a progressive scale.

1.4. Modernization of electronic accounting rules

The criteria for maintaining accounting records electronically will be incorporated directly into the law, without reference to a subsequent regulatory text. The objective is to secure the legal framework for the digitization of accounting.

1.5. Harmonization with business difficulty procedures

The tax provisions are aligned with the new procedures provided for by the Commercial Code:

prior notification to the administration in the event of a request to open safeguard proceedings,
accelerated tax rectification procedure,
obligation to provide information in the event of the opening of a receivership or liquidation procedure not initiated by the company.

1.6. Combined tax audit of natural persons

The administration can now proceed, under certain conditions, to a combined control relating simultaneously to:

the accounting review,
the examination of the individual's overall tax situation.

This control is governed by specific rules regarding duration, notification, and adversarial interviews.

1.7. Updating the rules of limitation in the case of conditional tax benefits

Taxpayers who have benefited from conditional tax advantages and who have provided guarantees may remain subject to the recovery of taxes, duties, fines, penalties and surcharges, even after the expiry of the limitation periods, in the event of non-compliance with the conditions attached to these advantages.

1.8. Simplification of the email address provided to the DGI

Taxpayers will be able to use a freely chosen email address (and no longer necessarily provided by a trusted service provider) for their electronic exchanges with the tax authorities.

1.9. Updating of stamp duties

As a continuation of the dematerialization, the 3 % discount granted to resellers of physical stamps is eliminated, this provision having become obsolete.

2. Corporate Income Tax (CIT)

2.1. Reform of the tax treatment of OPCCs

The tax regime for Undertakings for Collective Investment in Capital (UCITS) has been clarified. Distributions made by these vehicles will be taxed in the hands of the beneficiary according to the real economic nature underlying products:

dividends,
interests,
capital gains from disposal.

This reform aims to guarantee the tax neutrality of OPCCs and to avoid any artificial transformation of the nature of income for investors.

2.2. Revenues related to international shipping vessels

Lease fees and similar remuneration relating to the chartering, leasing or maintenance of vessels used in international maritime transport, when borne or recorded in the name of non-resident persons, benefit from a permanent exemption from withholding tax under the heading of IS.

2.3. Reporting obligation extended to rental income of non-residents

Non-resident companies without an establishment in Morocco, already required to declare capital gains on the sale of securities in Morocco, must now also declare income generated from renting out real estate.

2.4. Deduction of donations made to sports clubs

Companies will be able to deduct from their taxable income donations, in cash or in kind, made to sports clubs established in accordance with Law No. 30-09, up to the following limits:

of 20 % of taxable profit, And
of a ceiling of 5 million dirhams per financial year.

2.5. Contributions of assets by sports associations: extended exemption

The corporate income tax exemption applicable to asset and liability transfers from sports associations to sports companies has been extended. It now covers transfers made to the real value, and no longer solely at net book value.

In return, in the event of a subsequent sale of the contributed assets, the receiving company will have to include in its taxable income the capital gain calculated on the basis of the initial value of the assets.

2.6. Clarification of the five-year exemption for sports companies

The five-year total exemption from corporate income tax granted to sports companies (Law No. 30-09) is clarified: it applies from the first taxable sale, and not simply from the first year of operation. This clarification helps to secure the starting point of the exemption period.

2.7. Exclusion of the 40 % IS rate for certain microfinance institutions

Public limited companies resulting from the transformation of microcredit associations are no longer subject to the 40 % rate during their first five financial years of operation. They will benefit from the standard corporate income tax rate applicable to companies.

3. Income Tax (IR)

3.1. Payment of income tax on the sale of securities within 30 days

Taxpayers who sell securities, equity or debt instruments not registered with authorized intermediaries will now have to:

pay the income tax due for each transfer within 30 days following the transaction, via a notification slip, and
file a summary annual statement of all the transfers, which will also serve as the basis for claiming a refund of any excess tax.

3.2. Reclassification of OPCC distributions for IR

Distributions made by UCITS corresponding to capital gains realized by the fund are classified as profits from movable capital. This measure ensures consistency between the treatment of these products under corporate income tax and personal income tax, and offers better tax transparency for individual investors.

3.3. Gradual reduction on the salaries of professional athletes

To support the professionalization of sport, a specific tax allowance will be applied to income paid by sports companies to professional athletes, educators, coaches and technical teams:

90 % for the year 2026,
80 % for the year 2027,
70 % for the year 2028,
60 % for the year 2029.

3.4. Tax advantage for taxpayers in CPU upon cessation of activity

Individuals subject to the Single Professional Contribution (CPU) scheme, not benefiting from any pension scheme and aged at least 65 years old On the date of cessation of their activity, they benefit from:

50% reduction % regarding the capital gain related to the intangible assets of the business,
within the limits of 1,000,000 DH.

3.5. Extension of exemptions to CIMR supplementary pensions

The exemptions previously reserved for certain pensions and life annuities are extended to pensions and annuities paid within the framework of group supplementary retirement insurance contracts managed by CIMR, under the same conditions as the basic schemes. This measure strengthens fairness between the different categories of private sector retirees.

3.6. Tax regime for employees of Casablanca Finance City (CFC)

The flat rate of 20 % applicable to the salaries and wages of employees of companies benefiting from CFC status now applies:

for a maximum duration of 10 years,
on continuous or discontinuous periods of work within the companies concerned.

Employees may, by irrevocable option, choose to be taxed according to the progressive tax scale, provided they notify their employer of their choice before the 1^er FEBRUARY of the year in question. CFC companies must attach to their annual declaration of salaries and wages a statement listing the employees benefiting from the scheme.

3.7. Revaluation of the deduction for family expenses

The amounts relating to the deduction for family expenses are updated:

Amount per dependent: 600 DH (instead of 500 DH),
Overall annual limit: 3,600 DH (instead of 3,000 DH).

4. Value Added Tax (VAT)

4.1. Extension of the exemption for sports companies (2026–2030)

The VAT exemption granted to sports companies is extended for a further period of five years, of the 1^er January 2026 to December 31, 2030, in order to allow the new structures to consolidate.

4.2. Harmonization of exemption periods for investment goods

The VAT exemption scheme for investment goods is simplified:

Initial duration: 36 months,
Possible extension: 24 additional months, whether for local purchases or imports, under certain conditions.

4.3. Framework for formalities for imported capital goods

Import purchases of capital goods under investment agreements are subject to specific regulatory procedures (implementing decree), in order to secure the use of the exemption.

4.4. Extension of the exemption to agricultural inputs

The VAT exemption is extended to all fertilizers and growing media for agricultural use as defined by law no. 53-18. The objective is to align the tax treatment of all agricultural inputs and to reduce the acquisition cost for farmers.

4.5. Reverse charge of VAT on the purchase of waste and metals

Industrial companies subject to VAT must now apply the mechanism of self-assessment on their purchases of new industrial waste, metals, and other recovered materials. They will have to:

declare the VAT due on their turnover declaration,
and deduct it simultaneously on the same tax return.

4.6. Exemption for short pasta

THE short, uncooked, and unstuffed pasta are added to the list of products exempt from VAT without right to deduction, alongside bread, couscous, semolina, flours intended for human consumption and certain yeasts.

4.7. VAT exemption (with right to deduct) for blood and its derivatives

Blood and its derivatives are exempt from VAT with the right to deduct input tax, including on import, which reduces the cost of these sensitive products while preserving tax neutrality for the operators concerned.

5. Registration fees

5.1. Public procurement: introduction of a 0.1 % duty

Public procurement, initially subject to mandatory and free registration, now supports a registration fee of 0.1 %, due by the successful bidder, in order to improve traceability and access to information for the tax authorities.

5.2. Harmonization of rights regarding guarantees and releases

Secured credit transactions (guarantees, mortgages, pledges) and their releases all benefit from a a single fixed fee of 200 DH, regardless of the nature of the lending institution (credit institution, similar organization or financing company).

5.3. Additional fee of 2 % in case of untraceable payment

An additional registration fee of 2 % is established for transfers of ownership for valuable consideration exceeding 300,000 dirhams:

of real estate or real property rights,
or business assets,

This right applies only to the portion of the price paid under non-compliant conditions when the payment methods used are untraceable or not mentioned in the transaction.

5.4. Expansion of exempted transactions

Several categories of documents are exempt from registration fees, including:

certain real estate acquisitions for social use by social welfare institutions,
the transfer of assets within the framework of the restructuring of corporate groups,
certain transfers of shares or stock, subject to justification that they are not transparent real estate companies or companies whose assets consist primarily of real estate,
Credit agreements granted by credit institutions and similar organizations.

5.5. Tax rate of 5 % on transfers of shares in unlisted real estate companies

Transfers, whether for consideration or free of charge, of shares or units held in unlisted real estate companies and companies whose assets consist primarily of real estate are subject to a rate of 5 %.

5.6. Fixed fee of 1,000 DH for group restructuring operations

Companies that have opted for the group restructuring tax regime benefit from fixed fee of 1,000 DH on asset transfers carried out within this framework.

The information presented in this article is provided for general informational purposes only.
For an analysis tailored to your situation or that of your company, it is recommended to consult us directly in order to obtain specific support that is in line with your context.