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HMRC internal manual

Double Taxation Relief Manual

HM Revenue & Customs
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Morocco: Dividends

Moroccan tax deducted from dividends paid by a Moroccan company at the agreement rate of 25 per cent (10 per cent if the dividend is paid to a United Kingdom resident company controlling at least 10 per cent of the capital of the company paying the dividend) qualifies for credit as a direct tax (see INTM164010(c)).

The reductions to the above rates are not given where the dividends are effectively connected with (see INTM153110 fifth sub-paragraph) a permanent establishment which the recipient has in Morocco.

Where the recipient of the dividend is a United Kingdom company controlling, directly or indirectly, not less than 10 per cent of the voting power in the Moroccan company paying the dividend, credit may also be given for the underlying tax (see INTM164010(d) and Article 22(1)).