The Kingdom received just one recommendation in the OECD’s 2026 peer review reports on country-by-country reporting, published under the OECD/G20 project on base erosion and profit shifting (BEPS). The recommendation concerns the exchange of information between tax authorities.
The report states that Morocco continues to meet all terms of reference relating to its domestic legal and administrative framework and the appropriate use of country-by-country reports.
Morocco’s reporting requirements apply to fiscal years beginning on or after January 1, 2021. The consolidated revenue threshold triggering the obligation is set at 8.1225 billion dirhams. Groups subject to the rules must file their reports within 12 months of the end of the reporting fiscal year.
The framework allows a surrogate parent entity to file the report, while the requirement for local filing is suspended. Morocco’s domestic legal framework was first reviewed in 2020-2021.
One outstanding issue: establishing exchange agreements
The OECD’s assessment found no new recommendations on these aspects. The only remaining issue concerns arrangements for exchanging country-by-country reports with partner jurisdictions.
According to the report, Morocco has no bilateral relationships for exchanging these reports. The OECD therefore recommends that the Kingdom establish eligible agreements between competent authorities and qualifying members of the Inclusive Framework that meet the required standards for confidentiality, consistency and appropriate use of the data.
These agreements must be in place with jurisdictions with which Morocco has an international agreement allowing the automatic exchange of tax information. The recommendation thus focuses on the operational arrangements needed to transmit reports between tax administrations.
The issue is not new. It has remained unchanged since the 2019-2020 peer review, meaning the OECD’s concern has persisted across several assessment cycles.
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The report does, however, note a positive development: Morocco has established the necessary mechanisms or written procedures to ensure that information is exchanged in accordance with the terms of reference. This distinguishes the existence of domestic procedures from the effective establishment of exchange relationships with other jurisdictions.
The recommendation does not challenge the overall compliance of Morocco’s framework. It specifically concerns the establishment of eligible agreements between competent authorities, which are needed to enable the exchange of reports with relevant partners.
Country-by-country reporting falls under Action 13 of the OECD/G20 BEPS project. This minimum standard aims to strengthen tax transparency by requiring large multinational groups to provide information on the geographical distribution of their activities, revenues and taxes.
The information includes revenue, profit before tax, income tax due and paid, employee numbers, share capital, accumulated earnings and tangible assets. Groups must also identify their constituent entities in each jurisdiction and specify the nature of their activities.
As a general rule, the ultimate parent entity files the report with the tax authority in its country of residence. That authority then automatically transmits the information to jurisdictions where the group has constituent entities that are tax residents.
142 jurisdictions reviewed
The transmission of reports relies on an international agreement, which may take the form of the Multilateral Convention on Mutual Administrative Assistance in Tax Matters, a double taxation agreement or a tax information exchange agreement. An eligible agreement between competent authorities must also establish the operational terms for exchanging the information.
This is precisely the area covered by the recommendation to Morocco. Through its annual peer reviews, the OECD assesses implementation of the minimum standard across three components: the domestic legal and administrative framework, the exchange of information, and the confidentiality and appropriate use of reports.
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The 2026 compilation covers 142 jurisdictions that submitted legislation or information on their implementation of country-by-country reporting. More than 120 have now incorporated the reporting obligation into their domestic laws.
In total, 19 jurisdictions received a general recommendation concerning the introduction or completion of their legal or administrative frameworks. Another 25 received one or more recommendations on specific aspects of implementation.
Regarding information exchange, 110 jurisdictions reviewed had established bilateral or multilateral agreements between competent authorities. On confidentiality, 106 had been assessed by the Global Forum on Transparency and Exchange of Information for Tax Purposes without being advised to implement an action plan.
Meanwhile, 94 jurisdictions provided detailed information enabling the Inclusive Framework to verify that measures were in place to ensure the appropriate use of country-by-country reports.
