You live in France and rent out an apartment in Tangier or Chefchaouen? You are a shareholder in a Moroccan company and live in Paris? You are planning your retirement in Morocco? In all these situations, the same question arises: which country has the right to tax you?
The answer lies in the France-Morocco tax treaty signed on May 29, 1970, as amended by the protocol of August 18, 1989. It allocates taxing rights between the two countries, income by income, and provides for the elimination of double taxation.
Although little known, it can be a source of significant savings, provided it is applied correctly. This article reviews the most common situations for French-Moroccan dual nationals, Moroccans living abroad (MRE) and investors.
Step one: determine your tax residence
Before knowing where an item of income is taxed, you need to know in which country you are tax resident. Each country applies its own criteria (in France as in Morocco: household, main place of stay, centre of economic interests…). The same person may therefore be considered resident in both countries at once.
In that case, the treaty settles the matter by applying successive criteria:
| Order | Criterion |
|---|---|
| 1 | Permanent home |
| 2 | Centre of vital interests (closest personal and economic ties) |
| 3 | Habitual abode |
| 4 | Nationality |
For a French-Moroccan dual national, nationality only comes into play as a last resort. What matters first is where you actually live.
Rental income: taxed where the property is located
Income from real estate is taxable in the country where the property is located.
| Situation | Taxation |
|---|---|
| Resident in France, property let in Morocco | Taxed in Morocco. Declared in France, with a tax credit equal to the French tax |
| Resident in Morocco, property let in France | Taxed in France, under the rules for non-residents |
In practice, for a French resident, Moroccan rental income must be declared in France (form 2047), but the corresponding French tax is neutralised by the tax credit. It is, however, taken into account to calculate the tax rate on your other income.
The same logic applies to the capital gain on the sale of the property: it is taxed in Morocco (TPI, tax on real estate gains) and must be declared in France.
Dividends: a little-known advantage for French residents
Dividends are taxable in the shareholder's country of residence, but the company's country may levy a withholding tax capped at 15% of the gross amount.
Dividends paid by a Moroccan company to a French resident
- In Morocco withholding tax at the Moroccan rate, i.e. 11.25% in 2026 and 10% from 2027 (below the 15% cap).
- In France the dividends are taxable, but the treaty grants a flat-rate tax credit of 25% of the gross dividend, regardless of the rate actually withheld in Morocco.
This 25% credit exceeds the French income tax due on these dividends under the flat tax (PFU, 12.8%). In practice, French income tax is therefore fully neutralised. French social security contributions, however, remain due.
Dividends paid by a French company to a Moroccan resident
- Exemption from French withholding tax, provided the dividends are actually taxable in Morocco in the beneficiary's name.
- The claim is made using form 5000-FR, certified by the Moroccan tax authorities.
Watch out: the French courts check this condition closely. In 2026, the Paris Administrative Court of Appeal refused the exemption to a holding company based in the Tangier offshore centre, which was subject to low taxation in Morocco.
Retirement pensions: it all depends on their origin
| Type of pension | Country of taxation |
|---|---|
| Private-sector pension (general scheme, supplementary pensions) | Retiree's country of residence |
| Public-sector pension (civil servants, military personnel…) | Country paying the pension, unless the retiree holds only the nationality of the other country |
Private-sector retirees settled in Morocco: a very attractive tax regime
Their French pension is taxable only in Morocco, which provides for:
- a 70% allowance on the annual portion of the pension up to MAD 168,000, and 40% above that;
- an 80% reduction in the tax due on the portion of the pension transferred to Morocco on a permanent basis, into a non-convertible dirham account.
With these two advantages combined, the effective tax rate on a private-sector pension becomes very low.
To benefit from the 80% reduction, the retiree must attach to their annual tax return a certificate from the pension fund and a bank transfer certificate.
Salaries: taxed where the work is performed
Salaries are taxable in the country where the work is actually performed.
| Situation | Taxation |
|---|---|
| Employee working in Morocco for a Moroccan company | Morocco |
| Employee working in France for a French company | France |
| Temporary assignment of less than 183 days in the other country, paid by an employer not established in that country | Country of residence |
Public-sector remuneration (State employees, local authority staff…) generally remains taxable in the country that pays it.
Summary
| Income | French resident with Moroccan income | Moroccan resident with French income |
|---|---|---|
| Rental income | Taxed in Morocco + declared in France (tax credit) | Taxed in France |
| Dividends | Withholding tax in Morocco (10% to 11.25%) + 25% tax credit in France | Exemption from French withholding tax if taxable in Morocco |
| Private-sector pension | Taxed in France | Taxed in Morocco (allowance + 80% reduction) |
| Public-sector pension | Taxed in Morocco (if paid by the Moroccan State) | Taxed in France (if paid by the French State) |
| Salaries | Country where the work is performed | Country where the work is performed |
Worked example
Karim is tax resident in France. He owns an SARL (limited liability company) in Morocco, which pays him a gross dividend of MAD 100,000 in 2027.
| Step | Amount |
|---|---|
| Withholding tax in Morocco: 100,000 × 10% | MAD 10,000 |
| Theoretical French income tax (flat tax, PFU): 100,000 × 12.8% | MAD 12,800 (euro equivalent) |
| Treaty tax credit: 100,000 × 25% | MAD 25,000, capped at the French income tax |
| French income tax remaining due | 0 |
In total, Karim pays only 10% income tax (withheld in Morocco), plus French social security contributions.
Without the treaty, he would have borne both the Moroccan withholding tax and French income tax.
Frequently asked questions
I live in France and rent out an apartment in Morocco: do I have to declare it in France?
Yes. The rental income is taxed in Morocco, but it must be declared in France. The tax credit prevents you from paying tax twice.
I am a dual national: am I taxed in both countries?
No. Dual nationality does not create double taxation. What counts is your tax residence, determined by where you actually live.
Is my private-sector pension taxed in France if I move to Morocco?
No. Once you are tax resident in Morocco, your private-sector pension is taxable only in Morocco. Remember to inform your pension fund so that it stops applying French withholding tax.
Is my French civil service pension taxed in Morocco?
No, in principle it remains taxable in France, unless you hold only Moroccan nationality.
How can I avoid withholding tax on French dividends?
By being resident in Morocco, actually taxed in Morocco on those dividends, and by providing the company with form 5000-FR certified by the Moroccan tax authorities.
Conclusion
The France-Morocco tax treaty is a valuable tool for anyone whose life and assets are split between the two shores of the Mediterranean. Properly applied, it prevents double taxation and can even generate real advantages: a 25% tax credit on Moroccan dividends and a very favourable tax regime for private-sector retirees settled in Morocco.
However, its rules are old, technical and often misapplied: tax residence incorrectly determined, forms overlooked, income not declared in one of the two countries. Each situation deserves to be reviewed with a professional who masters both tax systems.