Morocco published Ministerial Decree No 423.21 which effectively reduces the maximum interest rate for loans from shareholders to 1.63%.
In 2020, the rate was 2.23%.
There is a 0.6% reduction in the interest rate for 2021.
In addition to this reduction, in Morocco, interest on loans from shareholders is only deductible if the share capital of a company has been fully paid up. If not, deduction of interest expense is disallowed.
There is also the limitation that interest expense on the amount of a loan cannot exceed the borrowed share capital. For example, interest on loans in excess of a debt-to-equity ratio of 1:1. Any interest related to the part which exceeds the amount of share capital is not tax-deductible.
Related Reading: “Morocco – Japan Tax Treaty Update”
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