OECD peer review clears Morocco’s country-by-country reporting rules, flags exchange gap

Morocco’s legal and administrative framework for country-by-country reporting meets all the terms of reference of the international standard, the OECD concludes in its ninth annual peer review, published this month. The organisation leaves the kingdom with one recommendation: to bring agreements for exchanging those reports into force.

The compilation, approved in October by the Inclusive Framework on Base Erosion and Profit Shifting (BEPS), covers 142 jurisdictions. It assesses how each applies Action 13, which requires large multinational groups to report their profits, taxes and activities every year in each country where they operate.

One recommendation, unchanged since 2019

On the domestic framework and on the appropriate use of the data, the report records that “Morocco confirms that its rules have not changed and continue to be applied effectively”. Neither area draws a recommendation.

On exchange, however, the OECD notes that Morocco “has no bilateral relationships in place for the exchange of CbC reports”. It recommends that the country put qualifying competent authority agreements in effect with Inclusive Framework members that meet the confidentiality, consistency and appropriate-use conditions, and with which Morocco already has an instrument allowing automatic exchange of tax information. The recommendation has stood since the 2019-2020 review.

Morocco has nonetheless put in place the written procedures needed for exchanges, once activated, to run in line with the terms of reference, the report adds.

A threshold of 8.12 billion dirhams

According to the country page, the filing obligation applies to fiscal years beginning on or after 1 January 2021 for groups with consolidated revenue of at least 8,122.5 million dirhams, with a filing deadline of twelve months after the end of the fiscal year.

Filing through a surrogate parent entity is permitted, while the local filing requirement is suspended. Morocco’s domestic framework was first reviewed in the 2020-2021 cycle.

110 jurisdictions already exchanging

Worldwide, more than 120 jurisdictions now have a domestic legal framework for country-by-country reporting and 110 have multilateral or bilateral competent authority agreements in place. Nineteen jurisdictions receive a general recommendation to put in place or finalise their framework, and 25 receive recommendations on specific points.

Activating automatic exchange is therefore the remaining step before Morocco’s tax administration can receive the reports of foreign groups operating in the country, a point the next peer review will measure again.