Morocco Formalizes Transfer Pricing Documentation Requirements
Morocco’s Council of Government approved in late 2025 a Decree establishing formal transfer pricing documentation requirements aligned with OECD BEPS Action 13 standards. Moroccan entities belonging to multinational groups meeting the threshold criteria must now prepare and maintain a Master File and a Local File, available for production upon DGI (Direction Générale des Impôts) request.
Who Is Subject to These Requirements
The obligation applies to Moroccan entities that are members of a group whose consolidated global turnover exceeds MAD 200 million (approximately €18 million). This threshold captures the vast majority of international groups with Moroccan subsidiaries, joint ventures or permanent establishments.
Required Documentation Content
The Master File must describe the group’s global organizational structure, business activities, intangibles, intercompany financing arrangements and the group’s global transfer pricing policies. The Local File must document each material intercompany transaction involving the Moroccan entity, including functional and risk analysis, selection and application of the most appropriate transfer pricing method, and benchmarking studies.
DGI Audit Exposure and Penalties
Failure to maintain adequate documentation strengthens the DGI’s position in transfer pricing adjustments by reversing the burden of proof. Penalties for non-disclosure reach 50% of the additional tax assessed, and the statute of limitations can be extended from four to ten years where fraud is established. Groups should prepare documentation proactively rather than reactively.
Our firm assists multinational groups in preparing Morocco-compliant transfer pricing documentation and defending positions before the DGI.
