Japan, Morocco sign tax treaty

On January 8, 2020, the governments of Japan and Morocco signed a tax treaty in Rabat, Morocco.

Under the treaty, dividend payments would be subject to a withholding tax rate of five percent if the beneficial owner holds at least ten percent of the voting power (in case of Japanese residents), or the capital of the company (in case of Moroccan residents). The rate is ten percent in all other cases.

Interest payments would be subject to a withholding tax rate of ten percent.

Royalty payments would be subject to a withholding tax rate of five percent of the gross amount of the royalties for the use of, or the right to use, industrial, commercial, or scientific equipment. The rate is ten percent in all other cases.

Gains from the alienation of shares representing at least fifty percent of the capital of a company may be taxed in the source country subjected to the maximum rate at the five percent. However, gains derived from changes of ownership that would directly result from a corporate reorganisation of that company or that alienator will be exempt from tax.

The treaty includes an article entitled Entitlement to Benefits, under which, a tax treaty benefit would be denied if it is reasonable to conclude that obtaining such a benefit was one of the principal purposes of any transaction.
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The treaty would come into force after both countries complete their necessary domestic procedures.

See Tax Treaty between Japan and Morocco