1. 1. 80% Allowance: Conditions and Mechanism
Article 76-I-2° of the Moroccan CGI provides an 80 % allowance on the amount of pensions and life annuities of foreign source received in Morocco by resident taxpayers, provided these amounts are transferred to a non-convertible dirham account. This provision aims to attract foreign retirees and returning MREs by guaranteeing ultra-favorable taxation.
Cumulative Conditions
Three conditions must be met: (a) Moroccan tax residence (stay > 183 days/year, permanent home in Morocco, or main professional activity in Morocco); (b) foreign-source pension (retirement fund outside Morocco: CNAV France, ONP Belgium, INSS Spain, Deutsche Rentenversicherung Germany, etc.); (c) actual transfer in non-convertible dirhams to a Moroccan bank account (CCMRE or MAD savings account).
Numerical Example (French Pension EUR 2,800/month)
Monthly pension: EUR 2,800 × MAD 11/EUR = MAD 30,800/month or MAD 369,600/year. 80 % allowance = MAD 295,680 non-taxable. Tax base: MAD 73,920/year = MAD 6,160/month. Applying 2026 IR brackets: tax due ≈ MAD 5,720/year (effective rate < 2 % of gross). Without allowance, tax would have been ≈ MAD 87,000/year — savings of MAD 81,000/year thanks to the allowance.
Pensions Excluded from the Scheme
Moroccan-source disability pensions (CNSS): not eligible, subject to the standard scale with a specific 60 % allowance. Salaries received from abroad: not eligible (the allowance only covers retirement pensions, not activity compensation). Dividends and interest received abroad: not eligible (specific capital income regime).
2. 2. Double Taxation Treaties: Who Taxes What
Morocco has signed over 50 bilateral tax treaties avoiding double taxation. For pensions, the general rule (OECD model) attributes taxing rights to the retiree's country of residence. So: an MRE who returned to Morocco receiving a French pension is taxable in Morocco (and benefits from the 80 % allowance), not in France.
France-Morocco Treaty (1970, revised 2009)
Article 18: private pensions taxable only in the State of residence (Morocco for returning MREs). Exception article 19: public pensions (civil servants, military) remain taxable in the paying State (France). Exemption mechanism in France: form 5000-FR (Moroccan tax residence certificate) to be provided to the French retirement fund for source exemption.
Belgium-Morocco Treaty (1972, revised 2006)
Article 18: private pensions taxable in the State of residence (Morocco). Article 19: Belgian public pensions taxable in Belgium. Moroccan tax residence certificate form (276 Conv) to be transmitted to ONP (Belgian Office of Pensions) for source exemption.
Spain-Morocco Treaty (1985)
Article 18: private pensions taxable in the State of residence. Public pensions taxable in the paying State (Spain). Treaty application request with INSS (form 7000-ES adaptation) to avoid Spanish source withholding.
3. 3. MRE Reporting Obligations in Morocco
Even with the 80 % allowance, an MRE receiving a foreign pension must declare worldwide income annually in Morocco.
Annual Declaration (before March 1, N+1)
Form ADC 010-F-15 (Annual Income Declaration for Individuals) to be filed online via SIMPL-IR or at a DGI branch. Mandatory mention: gross foreign pension + amount transferred in non-convertible MAD (bank proof) + 80 % allowance calculation + additional worldwide income (dividends, interest, rentals).
Supporting Documents to Keep (10 Years)
Annual payment certificates from the foreign retirement fund (CNAV France, ONP Belgium, INSS Spain). Moroccan bank statements showing CCMRE deposits. Foreign tax notice (if applicable) showing source exemption. Moroccan tax residence certificate forms validated by DGI.
Risks of Non-Declaration
Penalty of 15 % of the unreported amount + surcharge of 5 % per month of delay (capped at 30 %). In case of fraud (intentional concealment), criminal prosecution up to MAD 25,000 fine + permanent loss of the 80 % allowance benefit.
4. 4. Special Cases: Active MRE (Non-Retired)
The 80 % allowance only applies to retirement pensions. Active MREs (salaried employees abroad returning to Morocco while keeping foreign remote employment, self-employed, freelancers) cannot benefit from it on their activity compensation. Applicable regime: standard IR scale on net salaries after social contributions + 25 % professional allowance (capped at MAD 35,000/year). Under bilateral treaty, source exemption from the employer country if Moroccan tax residence certificate is provided.
5. FAQ
Q.How does the 80% allowance on MRE pensions work in 2026?
Q.Am I taxed in France or in Morocco on my French pension?
Q.Must I declare the foreign pension in Morocco even with the allowance?
Q.Do public pensions (civil servants) also benefit from the allowance?
Q.Does my foreign salary worked remotely from Morocco benefit from the 80% allowance?
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