OECD Recommendations for Morocco's Tax Reporting System
In its latest report, the Organisation for Economic Co-operation and Development (OECD) has recommended that Morocco take decisive steps to establish qualified agreements with relevant authorities in member countries. This initiative is part of a broader framework aimed at combating tax base erosion and profit shifting, facilitating the automatic exchange of tax reports related to multinational corporations. The report underscores that Morocco meets the requirements of the local legal and administrative framework governing these reports, alongside the necessary conditions for appropriate use of the information contained within them.
This recommendation is part of the "2026 Peer Review Report" concerning the implementation of country-by-country reporting standards, generated by the OECD under its project in collaboration with the G20 to tackle tax base erosion and profit shifting. The report monitors compliance with international rules aimed at enhancing tax transparency and addressing practices that could allow profits to be shifted away from countries where economic activities occur.
The report elaborates on the legal and administrative frameworks, mechanisms for information exchange, and measures concerning data confidentiality and proper use of tax reports. Notably, the recommendation directed at Morocco regarding agreements with relevant authorities has been reiterated since the peer reviews conducted in 2019 and 2020. It highlights that the Kingdom currently lacks active bilateral relationships for exchanging reports related to multinational corporations, based on the specific conditions outlined in the international standard, despite having written procedures or necessary protocols in place to ensure the exchange of information is compliant with established requirements.
A critical issue raised in the report pertains to completing the framework that enables Morocco to receive relevant tax reports from countries where subsidiaries of multinational groups operate, based on agreements that satisfy confidentiality, consistency, and proper use of information. The OECD calls upon Morocco to take necessary steps to establish these relationships with member countries, contingent upon the existence of an active international agreement for the automatic exchange of tax information between Morocco and the relevant countries, ensuring that the established arrangements meet the required conditions for exchanging country-by-country reports.
Furthermore, the report identifies the first fiscal year covered by Morocco's reporting system as those beginning on or after January 1, 2021, with a consolidated revenue threshold for groups set at 8.1225 billion dirhams. It notes that the deadline for submitting the report extends to 12 months following the end of the relevant fiscal year, with local filing obligations suspended, while allowing alternative submission of the report by a parent entity. The first review of Morocco’s local legal framework occurred during 2020 and 2021.
In general conclusions, the report indicates that over 120 countries and jurisdictions have incorporated country-by-country reporting obligations within their local legal frameworks. Among those reviewed, 110 countries have established bilateral or multilateral agreements with relevant authorities for information exchange, while 106 countries have undergone assessments by the Global Forum on Transparency and Exchange of Information for Tax Purposes regarding confidentiality and data protection safeguards in the context of implementing the automatic exchange of information standard. The report also reveals that 94 countries provided detailed information that allowed the comprehensive framework to secure adequate assurances regarding the existence of measures ensuring proper use of reports.
In light of the challenges facing tax systems due to globalization and digitization, country-by-country reports have gained particular significance. Multinational groups can operate economically in multiple countries, distributing revenue, costs, profits, and tax liabilities across various jurisdictions. The standard addressed in the OECD review aims to empower tax administrations with more comprehensive data regarding these distributions, aiding them in understanding the economic structure of groups and identifying risks that may necessitate additional tax examinations.
The reporting system is based on the preparation of an annual report that includes, for each tax jurisdiction in which the group operates, data on revenues, profits before income tax, taxes paid and due, the number of employees, reported capital, retained earnings, and tangible assets. Additionally, it is necessary to identify the subsidiaries of the group operating in each jurisdiction, specifying the nature of the activities each entity undertakes. This data allows tax authorities to compare the distribution of economic activity, profits, and taxes among the countries where the group is present.
Under the general mechanism adopted in this system, the ultimate parent company of the group typically prepares the report and submits it to the tax administration in the country where it is tax resident. That administration then automatically exchanges the report with the tax administrations of the countries included in the report as tax residence locations for the group’s subsidiaries, provided that the necessary international agreements and arrangements from relevant authorities are in place to complete the exchange. This means that the effectiveness of the system relies not only on the rules mandating reporting but also on the ability of countries to establish exchange relationships that meet the required legal and procedural criteria.
In this context, the report emphasizes the necessity for qualified agreements that ensure confidentiality, consistency, and proper use of information. This includes having an international agreement that allows for the automatic exchange of tax information, along with an active arrangement between relevant authorities that delineates the practical aspects of exchanging country-by-country reports. These conditions aim to ensure that expanding the exchange of information does not compromise data protection or lead to the reports being used outside their intended purposes.
The report asserts that Morocco already possesses the necessary written procedures to ensure the exchange of information operates within the established reference conditions; however, it lacks active bilateral relationships for exchanging country-by-country reports that meet the specified requirements. This point remains the focal recommendation retained by the OECD since the 2019 and 2020 reviews, while no changes have been noted in the assessment of the local legal and administrative framework or in the domain of proper use of information.
Overall, the review published in 2026 based its findings on the implementation status as of March 31, 2026, with the exception of information related to country-by-country report exchanges, which reflects the situation as of December 31, 2025. The comprehensive framework for combating tax base erosion and profit shifting adopted the report in October 2026, as part of an annual review process designed to monitor the implementation of the international standard and assess how well countries respond to previous recommendations.
As reported by lakome2.com.
