The most structural change in Morocco's Finance Law 2026 is the expansion of the withholding tax (retenue à la source, RAS) on service fees. From 1 July 2026, a much wider group of companies must withhold tax on the service invoices they pay - and a brand-new mechanism withholds part of the VAT itself.
This guide explains the progressive turnover threshold (Art. 247-XXXXVI CGI), the two stacking withholdings - RAS IS 5% and RAS TVA (75% / 100% of VAT) - the cash-flow impact on B2B billing, and the role of the attestation de régularité fiscale. For the full 2026 RAS picture, see our overview.
The new threshold: who must withhold?
Previously, the RAS on service fees paid to legal entities applied only to a narrow perimeter. The Finance Law 2026 extends it to service fees paid to legal entities (personnes morales) by:
- credit institutions and assimilated bodies;
- insurance and reinsurance companies;
- private companies above a progressive turnover threshold (CA HT): ≥ 500 MDH from 1 July 2026, ≥ 350 MDH from 2027, ≥ 200 MDH from 2028 (Art. 247-XXXXVI CGI).
In other words, once your business crosses the threshold for the current phase, you become a third-party tax collector: on every service invoice you pay to another company, you must withhold the RAS and remit it to the DGI on the supplier's behalf. The turnover to apply is that of the last closed financial year.
The measure targets legal-entity suppliers. Fees paid to individuals under a liberal profession (lawyers, accountants, etc.) were already subject to a 10% RAS under the pre-2026 regime; the 2026 change concerns B2B services between companies (and adds a 5% RAS IS - Art. 4 bis-I / 15 bis - on the HT amount).
The RAS IS: 5% on the HT amount
On top of being a "redevable" buyer, each service invoice from a legal entity (IS) now carries a 5% RAS IS on the HT amount. This is an advance on the supplier's corporate income tax, imputable against the supplier's annual IS (refundable if in excess). It is declared and paid via SIMPL-IS.
The RAS TVA: 75% or 100% of the VAT
Alongside the income-tax RAS, a new VAT withholding applies to the same operations. The rate depends on whether the supplier holds a valid attestation de régularité fiscale (ARF):
| Supplier status | VAT amount withheld |
|---|---|
| Valid ARF presented | 75% of the VAT |
| No valid ARF | 100% of the VAT |
The ARF is obtained via the DGI's Simpl-Attestation platform. Withholding and payment are made through SIMPL-TVA (tax.gov.ma).
Worked example: the cash-flow shock
A supplier issues a MAD 100,000 HT invoice to a large company, with 20% VAT (MAD 20,000). Total = MAD 120,000.
Case A - supplier has a valid ARF (75% VAT withholding):
Invoice HT 100,000
VAT (20%) 20,000
RAS TVA withheld (75% of VAT) -15,000
Net paid to supplier 105,000
Case B - no valid ARF (100% VAT withholding):
Invoice HT 100,000
VAT (20%) 20,000
RAS TVA withheld (100% of VAT) -20,000
Net paid to supplier 100,000
The supplier still recovers the withheld VAT through the normal VAT declaration (the withholding is an advance, not a loss) - but the cash-flow gap is immediate and real, especially for businesses with thin margins or long customer cycles. In Case B, the supplier receives zero net VAT on the invoice and must wait for the regularisation cycle.
Note: these figures isolate the VAT layer only. When the supplier is a legal entity (IS), the 5% RAS IS on the HT amount is withheld on top - so Case A would also deduct MAD 5,000 (100,000 × 5%) as an IS advance. See our worked-examples article for the full combined calculation.
Why this reform?
The DGI's objective is a structural shift from a declarative system to collection at source. By making large companies, banks, and insurers collect tax on the services they buy, the administration:
- secures revenue earlier and more reliably;
- improves the traceability of B2B financial flows;
- reduces under-reporting and informality in the service economy.
It aligns Morocco with international practice, where large taxpayers act as withholding agents - particularly relevant for multinational groups and foreign service providers (management fees, technical assistance, intra-group services).
Practical impact on businesses
- Accounts payable - update your process to identify suppliers subject to the RAS (legal entities) and apply the correct rate per invoice type.
- ARF management - request the attestation de régularité fiscale from every corporate supplier and track its validity; without it you must withhold 100% of the VAT.
- Cash-flow planning - suppliers will see their net receipts fall; pricing and payment terms may need renegotiation. The VAT reform context (now only two rates: 10% and 20%) makes the calculation cleaner.
- Corporate-tax interaction - the income-tax portion of the RAS is imputable against the supplier's annual IS; the VAT portion is regularised via the VAT return.
- Auto-entrepreneurs - the CPU regime has its own rules; check whether your status exposes you to the RAS or exempts you.
A note for foreign service providers
Payments for management services, consulting, and intra-group services to non-residents were already subject to RAS (10-30%). The 2026 broadening reinforces the trend: multinationals should reassess cost-plus and shared-services arrangements, ensure alignment with applicable tax treaties to avoid double taxation, and confirm whether their Moroccan client base crosses the progressive 500/350/200 MDH threshold.
The success of the reform depends on clear DGI guidance, smooth refund/credit mechanics, and coordination with treaty provisions. Until administrative practice matures, treat the 75% / 100% VAT withholding as a material cash-flow item in any large B2B contract.
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 (Art. 247) – finances.gov.ma
Disclaimer
This article is for general information only and does not constitute tax or legal advice. It is based on the Loi de Finances n° 50-25 for 2026 and the 2026 Code Général des Impôts. 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.
