Belgium-Morocco MRE Tax 2026: Treaty, IPP, Property Income

1. 1. Belgium-Morocco tax treaty: principles 1972 / 2006

The 1972 treaty (revised 2006, effective 1 Jan 2009) allocates taxing rights between Belgium and Morocco. For the Belgian MRE, six articles structure the essential rules.

Article 4 — Fiscal residence

Defines your primary taxation place by: (a) permanent home, (b) center of vital interests, (c) habitual abode (> 183 days), (d) nationality. Belgian-resident MRE: Belgian fiscal residence with worldwide taxation, except income exclusively allocated to Morocco.

Article 6 — Real estate income

Taxed EXCLUSIVELY in the State where the property is located. Moroccan apartment rent = taxed in Morocco, exempt in Belgium (with progressivity reserve).

Article 13 — Capital gains

Real estate capital gains taxed in the State of the property. Casablanca sale = taxed in Morocco (20 % rate or 30 % MRE allowance on primary residence).

Article 15 — Salaries

Taxed in the State of work. Belgian salary = taxed in Belgium only.

Article 18 — Private pensions

Taxed in the State of pensioner's residence. Belgian retiree settled in Marrakech = taxed in Morocco (with 80 % allowance under conditions).

Article 19 — Public pensions

Public pensions (Belgian State civil servants) taxed in the paying State, except for nationals of the other State.

2. 2. Belgian IPP declaration: part XIII foreign properties

Every Belgian fiscal resident owning a foreign property MUST declare it in part XIII (foreign properties) of the annual IPP return.

Section A — Address and description

Type (house, apartment, land, riad), full address, surface, acquisition year, acquisition price. For Moroccan property with melkia title: include title number.

Section B — Cadastral rental value (VLC)

For Moroccan property: include theoretical VLC set by Moroccan tax authorities. If rented: include annual gross rent. Converted to fictitious Belgian RC.

Section C — Mortgage

Borrowed capital, annual interest, duration. Although interest no longer deductible in all 3 regions since 2020, declaration remains mandatory.

Non-declaration penalty

EUR 50 to 1,250 per undeclared property per year. Retroactive regularization possible via DLU with 7-22 % partial amnesty.

3. 3. Moroccan rental income: taxation and declaration

You rent out an apartment in Casablanca, Tangier, or Marrakech from Belgium. Here's how rents are taxed.

In Morocco — IR on rental income

Annual gross rent < MAD 30,000: exempt. Rent MAD 30k-120k: 10 % final rate. Rent > MAD 120k: 15 %. Simpl-IR filing, deadline 30 April N+1. Possible source withholding by tenant for non-resident MREs.

In Belgium — progressivity reserve

Moroccan rents EXEMPT from Belgian tax (treaty article 6). BUT subject to progressivity reserve: they raise your Belgian marginal rate on Belgian income.

2026 practical case

Belgian Brussels salaried, EUR 50,000 gross salary. Marrakech apartment rented EUR 8,000/year. Morocco: IR = 8,000 × 0.10 = EUR 800. Belgium: declared in part XIII, exempt but marginal rate on 50,000 rises from 45 % to 47 % on top bracket → Belgian surplus ≈ EUR 200. Total: EUR 1,000.

4. 4. Retirement pensions: 80 % allowance in Morocco

If you retire and settle definitively in Morocco, your Belgian pension benefits from a major tax advantage.

Article 76-II of Moroccan tax code

80 % allowance on foreign pensions transferred definitively in non-convertible dirhams to Morocco. Conditions: (a) Moroccan fiscal residence > 183 d/year, (b) transfer via Moroccan bank, (c) Moroccan national or spouse.

Numerical example

Ex-Belfius retiree in Agadir, Belgian gross pension EUR 30,000/year. Without allowance: Morocco IR ≈ EUR 9,000. WITH 80 % allowance: taxable base = EUR 6,000, IR ≈ EUR 1,200. Annual saving: EUR 7,800. Over 25 retirement years: EUR 195,000 cumulative saving.

Procedure

(1) Establish fiscal residence in Morocco. (2) Request pension transfer from Belgian ONP. (3) Open non-convertible dirham account. (4) File annually via Simpl-IR.

5. 5. Moroccan housing tax (TH) and communal services tax (TSC)

You own a property in Morocco (occupied or rented): two annual taxes apply.

Housing tax (TH)

Due by occupant owner. Basis: theoretical annual rental value. Progressive rate 10-30 %. 75 % exemption on MRE primary residence for 5 years.

Communal services tax (TSC)

Due by every owner (rented or occupied). 10.50 % of rental value in urban areas, 6.50 % in peri-urban. Same 75 % MRE exemption.

Collection

Collection notice from Moroccan DGI. Payment via tax.gov.ma, Tarmid Banque, or Cash Plus. Deadline generally 31 December N. Late penalty: 10 % + 0.5 %/month.

6. 6. Real estate capital gains: 20 % or 30 % MRE allowance

You sell your Moroccan property from Belgium: how the gain is taxed.

General case

Gain = sale price - acquisition price - notary/agency fees - justified improvement expenses. Morocco IR 20 %. Paid at notarial signing.

MRE primary residence allowance

If the property was your primary residence in Morocco for at least 6 years before sale AND you sell as MRE: 30 % allowance on gross gain. Effective rate from 20 % to 14 %.

In Belgium

Moroccan real estate gain EXEMPT from Belgian tax (treaty article 13). But to declare in IPP part XIII for sale year.

7. 7. Transfers > EUR 10,000: declaration obligations

Belgium: transfer > EUR 10,000 outside EU → BNB and CTIF monitor. Prepare fund origin justification.
Morocco: incoming transfers UNLIMITED in convertible currency via legal channels.
If Moroccan resident sending OUTGOING > MAD 100,000 to Belgium: Office des Changes authorization required.
Keep all justifications for 5 years.

8. FAQ

Q.Are my Moroccan rents taxed in Belgium?

No, exempt under article 6 of the Belgium-Morocco treaty. BUT subject to progressivity reserve: they raise your Belgian marginal rate on Belgian income.

Q.What is the 80 % pension allowance in Morocco?

Article 76-II of Moroccan tax code: 80 % allowance on foreign pensions transferred definitively in non-convertible dirhams. Typical saving: EUR 7,000-10,000/year on EUR 30,000 gross pension.

Q.Must I declare my Moroccan apartment in my Belgian IPP?

Yes, MANDATORY in part XIII (foreign properties). Non-declaration penalty: EUR 50 to 1,250 per property per year. DLU regularization possible with 7-22 % amnesty.

Q.How many days can I spend in Belgium without losing MRE status?

For Morocco: < 183 days/year in Morocco → you remain MRE. For Belgium: > 183 days/year in Belgium → Belgian fiscal residence.

Q.What does a Belgian retiree settled in Marrakech pay on his pension?

Gross pension EUR 30,000/year: without allowance = Morocco IR ≈ EUR 9,000. WITH 80 % allowance = IR ≈ EUR 1,200. Saving EUR 7,800/year.

Q.Must I declare my Moroccan bank accounts to the BNB Central Contact Point?

Yes. Every Belgian fiscal resident must declare foreign accounts to PCC via form 276 CJC. No tax — just signaling.

Q.What notary fees to pay in Morocco to sell my property from Belgium?

Notary fees ≈ 0.5-1 %. Registration duties 4 %. IR capital gain 20 % (or 14 % with MRE allowance on primary residence).

Q.Can I avoid double taxation on my Belgian pension if I live in Morocco?

Yes. Treaty article 18 allocates pension taxation to residence State. Request a Moroccan fiscal residence certificate from Belgian ONP for exemption of Belgian withholding.

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