Billing address, payment method, IP address, telephone code: here are the new determining criteria for the application of digital VAT in Morocco. Recess is over! Your online purchases and dematerialized services will now be taxed. Get your wallets ready!
Your digital traces will now betray you to the Moroccan tax authorities. VAT will no longer spare your virtual transactions! The 2025 finance law brings major changes to the territoriality of value added tax (VAT).
Beyond the taxation of intangible services, digital commerce and cross-border services already introduced in 2024, this new reform aims to include more intangible operations within the scope of VAT.
One of the key changes concerns the criteria for establishing tax residence in Morocco for customers acquiring dematerialized services.
According to the Finance Law, a customer is now considered to have a tax domicile in Morocco if: “if he provides an address in Morocco for issuing the invoice, if he pays via a bank card issued by a Moroccan institution , if it uses a Moroccan IP address, if it uses the Moroccan international telephone code.
These new criteria aim to facilitate the identification by non-resident companies of Moroccan customers acquiring online services, in order to apply VAT to them as specified by the law, “in order to facilitate the identification by non-resident companies of the targeted customers in article 115 bis of the CGI which acquire remote services in a dematerialized manner.
The billing address, a new key criterion for determining tax domicile
One of the new criteria introduced by the 2025 Finance Law, to determine whether a customer has a tax domicile in Morocco, is linked to the billing address.
As mentioned above, “a customer is now considered to have a tax domicile in Morocco if he provides an address in Morocco for the issuance of the invoice”.
This criterion aims to facilitate the identification of Moroccan customers by non-resident companies providing dematerialized services.
Indeed, the billing address is often considered a reliable indicator of the customer’s place of residence or establishment. Take the example of a foreign company offering online consulting services. If a Moroccan customer orders these services and provides a billing address located in Morocco, the foreign company will then be required to apply Moroccan VAT to them, in accordance with the new provisions. This applies even if the customer is physically present in another country at the time of the transaction, as long as they use a Moroccan billing address. The billing address therefore takes precedence over the temporary geographic location of the customer.
This new criterion thus makes it possible to capture the added value generated by digital services provided to Moroccan customers, regardless of where the providers or customers are physically located at the time of the transaction. It should be noted, however, that the billing address is only one of the four criteria listed in the text.
Other criteria, such as the use of a Moroccan bank card, a Moroccan IP address or the Moroccan international telephone code, are also taken into account to determine the tax domicile. This multi-criteria approach aims to guarantee more precise identification of Moroccan customers, thus strengthening the efficiency of VAT collection on cross-border digital services.
Payment by Moroccan bank card, an additional indicator of tax domicile
Among the new criteria introduced to determine the tax domicile of a client in Morocco, is the use of a bank card issued by a Moroccan institution.
According to the 2025 Finance Law, “a customer is now considered to have a tax domicile in Morocco if he pays via a bank card issued by a Moroccan institution”.
This criterion complements other indicators such as billing address, IP address and telephone code, in order to more precisely identify Moroccan customers acquiring dematerialized services from foreign providers. Let’s take the example of a Moroccan customer residing in Casablanca, who wishes to subscribe to an online music streaming service offered by a foreign company.
During the payment process, he uses his bank card issued by a Moroccan bank. In this case, even if the customer does not provide a billing address in Morocco or does not use a Moroccan IP address (for example, if he is temporarily abroad), the fact that he pays with a card Moroccan bank will be considered as an additional indicator of its tax domicile in Morocco. From then on, the foreign company will be required to apply Moroccan VAT to the amount of the subscription, in accordance with the new provisions of the 2025 Finance Law.
This criterion linked to payment by Moroccan bank card thus makes it possible to capture certain transactions which could escape the other criteria, in particular when Moroccan customers make online purchases from abroad or use foreign networks. It should be noted, however, that this criterion is not absolute and must be considered in combination with the other indicators. For example, if a customer uses a Moroccan bank card but provides a billing address located in another country, other elements will have to be taken into account to determine their tax domicile.
Ultimately, this multi-criteria approach aims to guarantee as precise an identification as possible of Moroccan customers, in order to strengthen the efficiency of VAT collection on cross-border digital services and thus reduce tax disparities between local and international players.
The Moroccan IP address, a key geographic index
As part of the reform of the territoriality of VAT in Morocco, the use of a Moroccan IP address becomes a determining criterion for establishing the tax domicile of a customer. As stipulated in the 2025 Finance Law, “a customer is now considered to have a tax domicile in Morocco if he uses a Moroccan IP address”. This criterion is particularly relevant in the context of digital commerce and dematerialized services provided online.
The Internet Protocol (IP) address is a series of numbers that uniquely identifies a device connected to the Internet and helps determine its approximate geographic location. Let’s take the example of a Moroccan customer residing in Marrakech, who wishes to purchase software online from a foreign company. When browsing the company’s website, its IP address will be detected as Moroccan, thanks to the IP address ranges assigned to Morocco.
In this case, even if the customer does not provide a Moroccan billing address or does not pay with a Moroccan bank card, the fact that he uses a Moroccan IP address will be considered a strong indicator of his tax domicile in Morocco. From then on, the foreign company will have to apply Moroccan VAT on the amount of the sale of the software, in accordance with the new provisions of the 2025 Finance Law.
Although the IP address is not a perfect indicator (some VPN or virtual network services can hide or modify the apparent IP address), it remains a key criterion in the context of the new territoriality of VAT in Morocco.
In combination with other criteria such as billing address, payment method and telephone code, the IP address allows more precise identification of Moroccan customers acquiring digital services from foreign providers.
The Moroccan telephone code, an additional signal
Among the new criteria introduced by the 2025 Finance Law to determine the tax domicile of a client in Morocco, is the use of the Moroccan international telephone code.
As mentioned in the 2025 Finance Law, “a client is now considered to have a tax domicile in Morocco if he uses the Moroccan international telephone code”.
This criterion complements other indicators such as billing address, payment method and IP address, in order to more precisely identify Moroccan customers acquiring dematerialized services from foreign providers. Let’s take the example of a Moroccan consultant based in Rabat, who wishes to register for online training offered by a foreign company. During the registration process, he provides his mobile phone number starting with the Moroccan international dialing code +212.
In this case, even if the consultant does not provide a billing address in Morocco or does not use a Moroccan IP address (for example, if he is temporarily abroad), the fact that he uses a Moroccan number telephone number with the Moroccan international dialing code will be considered as an additional indicator of his tax domicile in Morocco. From then on, the foreign company will be required to apply Moroccan VAT on the amount of the online training, in accordance with the new provisions of the 2025 Finance Law.
This criterion linked to the Moroccan telephone code thus makes it possible to capture certain transactions which could escape the other criteria, in particular when Moroccan customers make online purchases from abroad or use foreign networks.
However, it should be noted that this criterion is not absolute and must be considered in combination with the other indicators. For example, if a customer uses a telephone number with the Moroccan country code but provides a billing address located in another country, other elements will have to be taken into account to determine their tax domicile. Objective: to guarantee as precise an identification as possible of Moroccan customers, in order to strengthen the efficiency of VAT collection on cross-border digital services.
Adapting taxation to the digital age
This new territoriality of VAT will impact many sectors and professions, due to their intangible or cross-border nature. Among these, we can cite: online training and distance education, online gaming and virtual reality services, telemedicine and remote medical consultation services, editing and publication services online, or even online data analysis and artificial intelligence services.
This list is not exhaustive, but illustrates the broad scope of this reform which aims to modernize Moroccan taxation to adapt it to the digital age.
Bilal Cherraji / ECO Inspirations
