Treaty detail
United States - MA tax treaty
A practical treaty page built around the official treaty text, key withholding categories, permanent-establishment rules, and article-level summaries.
Signed
1977-08-01
Effective
1981-12-30
Articles seeded
6
Withholding snapshot
Dividends
Individual rate: 15% · Corporate rate: 10%
The 10 percent corporate rate generally depends on direct ownership of at least 10 percent of the voting stock of the dividend payer. The 1977 treaty drafting and Moroccan domestic withholding rules require article-level review.
Interest
Rate: 15%
IRS Treaty Table 1 reflects a general 15 percent ceiling, with government, central-bank, and certain qualifying carve-outs available subject to article-level review.
Royalties
Rate: 10%
The Morocco treaty applies a 10 percent royalty ceiling on most categories. Article text controls for software, patent, and copyright classification, which can be unpredictable under Moroccan domestic law.
Permanent establishment
Construction threshold: more than 6 months
Dependent-agent analysis under the older 1977 wording can be triggered by stock-of-merchandise and agency rules that are narrower than modern OECD-style treaties.
Other treaty flags
Pension treatment is article-specific under the 1977 treaty, with government-service pensions and private pensions handled under distinct provisions.
Seeded article summaries
Article 4
Residence
Defines treaty residence and is the starting point for any claim to reduced withholding or treaty protection.
Residence under the Morocco treaty matters for U.S. consultants and engineering firms working on Moroccan infrastructure projects. Tie-breaker rules under the 1977 drafting broadly track OECD-style tests.
Article 5
Permanent Establishment
Sets the business-presence threshold that permits source-country taxation of business profits.
The Morocco treaty includes shorter construction and supervisory thresholds than many modern U.S. treaties. Dependent-agent analysis remains important and should be read against the older treaty wording.
Article 7
Business Profits
Generally reserves business profits to the residence state unless a permanent establishment exists in the other state.
This article matters for U.S. firms operating in Moroccan automotive, aerospace, and tourism sectors. Article 5 PE analysis must be completed before reliance on Article 7 protection.
Article 10
Dividends
Provides treaty limits on source-country dividend withholding in qualifying cases.
The dividend article's 10 percent and 15 percent ceilings are the quick snapshot, but Moroccan domestic withholding interactions and the article's ownership thresholds control the practical outcome.
Article 11
Interest
Limits source-country withholding on qualifying interest.
The Morocco treaty does not eliminate interest withholding outright. The 15 percent ceiling reflects 1977-era drafting, and government carve-outs may apply subject to article-level review.
Article 12
Royalties
Limits source-country withholding on qualifying royalties.
The royalty article applies a 10 percent ceiling on most categories. Software classification under Moroccan law and the article's treatment of mixed payments can affect outcomes for licensing arrangements.
Official text
Other treaties involving these jurisdictions
Computed from the cross-reference graph. Links open the related entity on this site.
This entry cites
- TreatyUS–GB treaty
- TreatyUS–CA treaty
- TreatyUS–DE treaty
- TreatyUS–FR treaty
- TreatyUS–JP treaty
- TreatyUS–NL treaty
- TreatyUS–AU treaty
- TreatyUS–KR treaty
Primary sources
- Morocco treaty documents pageVerified 2026-05-20
- Official U.S.-Morocco treaty PDFVerified 2026-05-20
- IRS Tax Treaty Table 1Verified 2026-05-20
- Treasury treaties in force listVerified 2026-05-20
Important disclaimer
This library is for general tax education only. Always verify filing obligations, due dates, and tax consequences against the cited primary source or with a qualified tax professional.