Theory only goes so far. This article walks through ten concrete, number-by-number scenarios of Morocco's 2026 withholding tax (retenue à la source, RAS), so you can see exactly who withholds, how much, and why. For the rules behind these examples, see our RAS 2026 overview.
The two key facts to keep in mind:
- RAS IS = 5% of the HT amount on services paid to legal entities (IS) - Art. 4 bis-I / 15 bis CGI.
- RAS TVA = 75% of the VAT (with a valid attestation de régularité fiscale, ARF) or 100% without it.
In this article
- The progressive turnover threshold
- Example 1: Bank pays a service company (with ARF)
- Example 2: Same invoice, no ARF
- Example 3: Doctor rents from an individual
- Example 4: Landlord regimes compared
- Example 5: CA 600 MDH vs 280 MDH
- Example 6: Auto-entrepreneur / CPU (30% trap)
- Example 7: Car-rental agency + Mohamed
- Example 8: Dividends (11.25%)
- Example 9: Honoraires to a liberal professional (10%)
- Example 10: Non-resident provider (treaty cap)
- Practical checklist
The progressive turnover threshold (who must withhold)
The obligation for private companies is phased in by turnover (CA HT, last closed financial year - Art. 247-XXXXVI CGI). Banks, insurers, the State and public establishments are redevable from phase 1 regardless of turnover:
| Phase | From | Private companies redevable if CA HT ≥ |
|---|---|---|
| 1 | 1 July 2026 | 500 MDH |
| 2 | 1 Jan 2027 | 350 MDH |
| 3 | 1 Jan 2028 | 200 MDH |
Example 1: A bank pays a service company (with ARF)
A bank (turnover in the billions, so redevable from 1 July 2026) hires a strategy consulting firm (SARL, subject to IS). Invoice: MAD 300,000 HT, VAT 20% (MAD 60,000). The firm provides a valid ARF. (For the full rules behind this, see our RAS on services guide.)
Two withholdings stack on the same invoice:
HT amount 300,000
VAT 20% 60,000
TVA gross (invoice total) 360,000
RAS IS 5% on HT (300,000 × 5%) -15,000 → income-tax advance for the firm
RAS TVA 75% of VAT (60,000 × 75%) -45,000 → VAT advance
Net paid to the firm 300,000
The firm declares 300,000 of revenue and recovers the MAD 15,000 as an IS credit; the MAD 45,000 VAT is regularised via its VAT return. The bank remits both withheld amounts to the DGI via SIMPL-IS and SIMPL-TVA before the end of the following month.
Example 2: Same invoice, but NO valid ARF
Same bank, same firm, same MAD 300,000 HT invoice - but the firm does not present a valid attestation. Only the VAT withholding changes (75% → 100%):
HT amount 300,000
VAT 20% 60,000
RAS IS 5% on HT -15,000
RAS TVA 100% of VAT (no ARF) -60,000 ← the firm loses 100% of the VAT
Net paid to the firm 285,000
The ARF lesson: without a valid attestation, the supplier receives zero net VAT on the invoice. A supplier that is up to date with the DGI should always deliver its ARF (obtained via Simpl-Attestation) to avoid this 25-point cash-flow penalty.
Example 3: A doctor rents an office from an individual (NO withholding)
Dr. X, an independent doctor (IR, liberal profession), rents her practice from Mr. Y, an individual who owns the premises and is taxed under the simplified rental regime (Art. 61-I CGI). Monthly rent: MAD 8,000.
Result: no 5% rental withholding applies, for two independent reasons:
- The tenant (Dr. X) is not a redevable entity. The 5% rental RAS (Art. 15 ter) is operated only by the State, public establishments, banks, insurers, and companies above the turnover threshold. A self-employed doctor is none of these.
- The landlord is under the simplified rental regime (Art. 61-I), which is excluded from the 5% measure regardless of the tenant.
Contrast: if the same premises were rented by a bank to a professional landlord taxed under RNR or RNS, the bank would withhold 5% on the HT rent. The measure turns on both the tenant's status and the landlord's regime.
See our rental withholding guide for the full scope.
Example 4: Comparing landlord regimes (who is/isn't subject to the 5% rental RAS)
Assume the tenant is always a redevable entity (e.g., a bank). The 5% rental withholding depends on the landlord's tax regime:
| Landlord | Regime | 5% rental RAS? |
|---|---|---|
| SCI / company | IS | Yes - 5% on HT rent |
| Individual professional landlord | IR - RNR or RNS | Yes - 5% on HT rent |
| Individual, casual landlord | Simplified rental regime (Art. 61-I) | No - excluded |
| OPCI (real-estate fund) | - | No - excluded |
| Leasing company (crédit-bail) | - | No - excluded |
| Entity with permanent IS exemption | Art. 6-I-A CGI | No - excluded |
Worked number: a redevable tenant pays MAD 50,000 HT rent (incl. MAD 2,000 TSC) to an SCI → RAS = 50,000 × 5% = MAD 2,500; net to the SCI = MAD 47,500. (TSC is part of the HT base.)
Example 5: CA 600 MDH vs 280 MDH (when does the threshold bite?)
Two industrial companies, both buying MAD 50,000/month of consulting from the same IS firm:
- Company A - CA 600 MDH. Above the 500 MDH phase-1 threshold → redevable from 1 July 2026. It withholds RAS IS 5% + RAS TVA on every invoice from that date.
- Company B - CA 280 MDH. Below 500 (2026) and below 350 (2027), but above 200 → only redevable from 1 January 2028 (phase 3). Until then, it pays its supplier normally with no withholding.
The turnover to apply is the CA HT of the last closed financial year before the payment. A company crossing a threshold mid-cycle becomes redevable from the legal phase date, not retroactively.
Example 6: Auto-entrepreneur / CPU supplier (the 30% trap)
A large company hires an auto-entrepreneur (CPU regime) for IT services. Monthly invoices: MAD 10,000 HT. The RAS on auto-entrepreneurs/CPU is 30%, but it only triggers once the cumulative amount paid to that supplier in the calendar year exceeds MAD 80,000 - assessed client by client (what the supplier bills its other clients is irrelevant):
Months 1-8 (MAD 10,000 × 8 = 80,000) → threshold not yet exceeded → NO withholding
Month 9 invoice (MAD 10,000) → threshold crossed → RAS 30% = 3,000 (prospective,
from this payment onward for this client)
Net paid in month 9 7,000
Other points worth knowing:
- Honoraires to a physical person under RNR/RNS (e.g., an independent lawyer): 10% RAS, due from any corporate payer since 2023, with no turnover threshold.
- Dividends distributed in 2026: 11.25% RAS - see our dividend guide.
- Non-resident providers: management/consulting fees paid abroad remain subject to RAS (10-30%, capped by any tax treaty) - confirm the treaty before payment.
Example 7: A car-rental agency rents a garage from Mohamed (no 5% RAS)
"Auto Maroc", a car-rental SARL subject to IS (annual turnover ~50 MDH), rents a garage to park its fleet from Mohamed, an individual who owns the premises and is taxed under the simplified rental-income regime (revenus fonciers, Art. 61-I / 160 bis CGI). Monthly rent: MAD 6,000. Auto Maroc is the tenant, Mohamed is the landlord.
Result: the new 5% rental RAS (Art. 15 ter) does NOT apply.
The Art. 15 ter 5% targets only rent paid to (a) legal entities subject to IS, or (b) physical persons in the RNR or RNS regime - that is, professional or company landlords (Art. 15 ter, 19-IV-A and 73-II-A CGI; DGI Note Circulaire n° 737). Mohamed, a casual individual landlord under the simplified revenus fonciers regime, is outside this scope, so the 2026 measure does not reach him.
The turnover threshold is NOT the reason. A frequent mistake is to think "the tenant is below the 500 MDH threshold, so no 5%". That threshold only gates the obligation when the landlord is a legal entity (IS). When the landlord is a physical person in RNR/RNS, any corporate tenant must withhold the 5%, regardless of its own turnover (Art. 157-I CGI). So if Mohamed were a professional landlord in RNR/RNS, Auto Maroc would withhold 5% - even with its modest ~50 MDH turnover.
What applies instead: Mohamed's rent is a revenu foncier, governed by the older Art. 61-I / 160 bis regime for rent paid to a physical person - a separate mechanism from the 2026 Art. 15 ter 5%. Its own rates apply: 10% for annual rent of 40,000-120,000 DH per landlord, 15% above 120,000 DH, or the optional 20% libératoire rate (since 2025), with a dispensation when the annual rent to a given owner is ≤ 40,000 DH. The headline point stands: the new 5% Art. 15 ter does not bite this rent.
Contrast: the same garage owned by an SCI (IS) or an RNR/RNS professional and rented by a bank → the 5% Art. 15 ter would apply.
Example 8: Dividends (the 11.25% rate and imputation)
A resident individual shareholder receives a MAD 80,000 gross dividend distributed in 2026 from a Moroccan SARL.
Gross dividend 80,000
RAS withheld at source (11.25%) -9,000
Net received 71,000
The 11.25% is not libératoire - it is an advance. At year-end the shareholder declares the 80,000 gross in their global IR; the 9,000 already withheld is imputed against the IR computed on the progressive scale. If the IR share for this income is lower than 9,000, the excess is refundable; if higher (e.g. a top-bracket taxpayer near 38%), a complement is owed. The rate is set by the year of distribution (11.25% in 2026, 10% in 2027). See our dividend guide.
Example 9: Honoraires to a liberal professional (the 10% rate)
An SME (turnover 30 MDH, well below any threshold) pays an independent lawyer (a physical person taxed under RNR) MAD 20,000 HT for legal fees.
Honoraires HT 20,000
RAS 10% (PP-RNR beneficiary) -2,000
Net paid to the lawyer 18,000
This 10% RAS on honoraires paid to a physical person under RNR/RNS (lawyer, accountant, architect, consultant…) has applied since 2023 and is owed by any corporate payer, with no turnover threshold. The 2,000 DH is an IR advance for the lawyer, imputable on their annual IR. (If the SME is itself redevable for the RAS TVA, the VAT layer may also apply - but the 10% income RAS is independent of the company's size.)
Example 10: Non-resident service provider (the treaty cap)
A Moroccan company pays a MAD 50,000 HT consulting fee to a foreign firm with no permanent establishment in Morocco.
- Domestic rate: services paid to non-residents are subject to RAS - commonly 10% for consulting/management fees (up to 20-30% for other categories such as royalties).
- Tax treaty: the relevant double-taxation treaty typically caps the withholding. The Moroccan payer must obtain a tax-residency certificate from the foreign supplier to apply the treaty rate.
Consulting fee HT 50,000
RAS at treaty rate (e.g. 10%) -5,000
Net paid abroad 45,000
Without a valid residency certificate, the Moroccan payer must apply the domestic rate (not the treaty rate); the supplier then claims any excess in its country of residence. Always confirm the treaty and the exact income category before paying.
Practical checklist
- Qualify each supplier - legal entity (IS), physical person RNR/RNS, or auto-entrepreneur/CPU - the rate differs.
- Collect the ARF from every corporate supplier; without it you withhold 100% of the VAT.
- Track your own turnover against the 500/350/200 MDH calendar to know when you become redevable.
- Remit on time - both RAS IS and RAS TVA are due via SIMPL before the end of the month following payment; late withholding is sanctioned by a 30% majoration (100% in case of bad faith).
When in doubt about a supplier's regime or a treaty rate, consult a certified accountant - the examples above are simplified for clarity.
Sources
- Direction Générale des Impôts (DGI) – tax.gov.ma
- Loi de Finances n° 50-25 pour 2026 – finances.gov.ma
- Code Général des Impôts 2026 – finances.gov.ma
Disclaimer
This article is for general information only and does not constitute tax or legal advice. Figures and thresholds are based on the Loi de Finances n° 50-25 for 2026, the Code Général des Impôts 2026 (Art. 4 bis, 15 bis, 15 ter, 117-V, 247-XXXXVI), and DGI Note Circulaire n° 737. Always confirm exact provisions with the DGI or a licensed advisor.
Marouan focuses on corporate taxation, VAT, and business compliance in Morocco. He writes practical guides that help entrepreneurs and companies navigate the Moroccan tax system with confidence.



