Conventions fiscales bilatérales de non-double imposition (réseau conventionnel marocain)

Morocco has an extensive treaty network (roughly 60 conventions in force: France, Spain, Belgium, Germany, UK, USA (1977), UAE, Qatar, Luxembourg, Netherlands, Switzerland, Turkey, China, most of West Africa...). Treaties typically reduce dividend WHT to 5%-10%-15% depending on the participation held by the beneficial owner, and generally allocate the right to tax capital gains on shares to the state of residence (with a real-estate-company carve-out). To apply the treaty rate at source rather than reclaim later, the investor must provide a TAX RESIDENCE CERTIFICATE issued for the year of distribution and be the BENEFICIAL OWNER (the LF 2025 hardened anti-abuse and beneficial-owner testing, art. 119 bis CGI). Where the domestic rate was over-withheld, a refund can be claimed from the DGI.