The Finance Bill for 2025 introduces major tax changes aimed at strengthening the control and transparency of collaborative economic structures in Morocco. Joint-stock companies (SEP) and economic interest groups (EIG) will be subject to new obligations, in particular their inclusion in the scope of corporate tax (IS). These reforms mark a turning point in the tax management of these entities.
Joint-stock companies (SEP) and economic interest groups (EIG) occupy a particular place in the Moroccan economy. These structures, often used to pool resources or carry out specific activities, have until now benefited from a separate tax regime. However, from 2025, they will be subject (in the absence of amendments to the PLF 2025 in the Chamber of Advisors) to a reinforced tax framework, including in particular the obligation for some of them to pay tax on companies (IS). These measures, carried by the 2025 Finance Bill (PLF), aim to harmonize tax practices, strengthen transparency and allow better control of the revenue generated.
A tax turning point for SEPs and GIEs
The PLF 2025 proposes a key reform: the inclusion of SEPs and GIEs in the scope of application of the IS, a first for these entities. Currently, SEPs without legal personality were excluded from this tax, except in the case of an irrevocable option. From now on, all SEPs comprising more than five natural person partners or at least one legal entity will have to comply.
As for GIEs, they will also be subject to IS, but with a particularity: their taxation will be calculated in the name of their members, according to their share in the group’s net income. This will make it possible to trace the revenues generated by these entities and ensure fairer taxation. This integration also aims to correct gaps in the monitoring of tax declarations: previously, the tax administration had no mechanism to check whether members of GIEs or SEPs correctly declared their share of income.
The stated objective of these measures is twofold: to strengthen transparency and limit tax abuse linked to these structures, which are often managed informally.
New accounting and reporting obligations
The strengthening of the tax framework is accompanied by new accounting requirements. SEPs, whether or not they are subject to IS, will now have to keep accounts in accordance with the standards in force. This obligation aims to guarantee better traceability of income and expenses, while allowing the tax administration to verify partners’ declarations more effectively.
For SEPs not subject to IS, the partners will be required to attach to their annual declaration the company’s accounting documents, allowing their share in the net results achieved to be determined. This measure makes members, whether natural or legal persons, responsible and puts an end to the fiscal opacity that surrounded these structures.
As for GIEs, this new regulation pushes them to adopt practices similar to those of other companies. Members, whether physical or moral, will have to include their share of results in their respective declaration, which aligns their tax treatment with a logic of transparency.
Questions about practical application
Despite this progress, certain points remain to be clarified, in particular the terms of declaration and payment of corporate tax for SEPs. The PLF 2025 presentation note specifies that the tax will be established in the name of the partner having the power to act on behalf of the SEP. However, questions remain regarding the role of this designated partner, especially if he is a natural person.
For example, will he have to include the tax result of the SEP in his personal income tax (IR) declaration? Or will he have to file a separate return on behalf of the SEP, with a separate tax identification number? These uncertainties raise concerns, in particular about the risk of double taxation or legal vacuum.
For the partners of the SEPs and GIEs, another question remains: how will the shares of the results be treated? If for legal persons, the situation seems clear – they will have to include their part in their own IS declaration –, the case of natural persons remains unclear. Will the shares be considered professional income or income from movable capital? So many gray areas which will have to be resolved by an application circular.
