The draft finance law for 2025, discussed before the Commission, provided for the establishment of a tax incentive regime in favor of FIFA representations in Morocco. Indeed, the International Football Federation will create an office in Morocco for 300 of its executives to settle there. They will stay at least until 2030, the date of the organization of the Football World Cup in Morocco, Spain and Portugal.
As these people pay their taxes in Switzerland, the government does not intend to subject them to double taxation, underlined Fouzi Lekjaâ. This is how the Minister in charge of the Budget wanted to include tax provisions sufficiently in advance, a way of giving Morocco an image of seriousness. The idea is to set up in Morocco a regional training center for coaches and other experts in the field of football such as those who support VAR so that this process is certified.
In Africa, there are two centers, one of which is located in Senegal. It should be noted that as part of FIFA’s support for the establishment of its permanent regional office in Rabat and to support the development of its activities in Morocco and the region, the PLF proposed to establish a regime tax incentive in favor of its representations. And this, for all activities and operations carried out in accordance with the statutes. This involves granting FIFA exemption from corporate tax, income tax, VAT and registration and stamp duties. Indeed, the permanent total exemption from IS, for these representations in respect of all activities or operations consistent with the object defined in its statutes, we read in the presentation note of the PLF.
Added to this is the exemption from tax withheld at source on income from shares, shares and similar income, for products distributed by the representations in Morocco to FIFA or to one of its affiliated entities. Ditto for the exemption from withholding tax on remuneration paid by these representations to FIFA or one of its non-resident affiliated entities. Without forgetting the exemption from VAT, internally and on importation, of goods, materials, merchandise and services acquired.
The exemption extends to registration and stamp duties for all documents passed by FIFA representations in Morocco including, where applicable, residence permits issued to representatives of this Federation and employees of its representations. in Morocco. Finally, the exemption will concern IR for salary and similar income for staff of FIFA representations in Morocco who do not have Moroccan nationality.
Public utility: A bill in the pipeline
During discussions within the Finance Commission, the principle of taxation of land profits made within the framework of the de facto expropriation procedure was clarified. In this matter, Lekjaâ tried to reassure parliamentarians. He announced that the Minister of Equipment and Water Nizar Baraka is putting the final touches to his bill on expropriation for public utility. He must present his new text at one of the next government councils.
Purchase of supplementary pensions
The Finance Committee also discussed the revision of the tax treatment of supplementary pension purchases from which contributions have not been deducted. As part of the harmonization of the tax treatment of long-term savings contracts, it is proposed to condition the benefit of the exemption of benefits provided at the end of supplementary retirement contracts to the obligation to conclude these contracts for a duration equal to 8 years. It is also a question of clarifying the terms of taxation of benefits relating to said contracts and those relating to life insurance or capitalization contracts, provided before the expiration of 8 years. In the event of death or disability of the person concerned, this period is not taken into account, like other long-term savings plans.
Withholding tax on compensation paid in matters of expropriation
As part of improving readability and interpretation, it is proposed to clarify the principle of taxation of land profits made following de facto expropriation or following any other transfer of ownership by a decision judicial having the force of res judicata, specifies the presentation note of the PLF.
This measure enshrines the principle of tax fairness, in the event of transfer of ownership of immovable property, whatever the procedure of this transfer, in order to avoid differences of interpretation and litigation. In this respect, it should be noted that the transfer of property following a judicial decision concerns, in addition to expropriation for reasons of public utility and by de facto action, other cases, such as pre-emption, public auction (seizure, exit from joint ownership)…
Furthermore, it is proposed to establish the obligation to make a withholding tax on compensation paid by persons involved in the payment of said compensation, with the possibility of deducting the amount withheld from the tax payable. and with the right to restitution, it is indicated.
Mohamed CHAOUI
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