Tax Law|23 min read

Morocco Tax Reassessment 2026: Procedure and Appeals

Check DGI notices, calculate each deadline and prepare a documented defence through to the administrative court.

Karim Bensouda

Legal Editor — Employment Law

Need a Tax Law lawyer?

Browse verified profiles near you

Browse the directory

Legal framework for tax reassessment in Morocco

adversarial tax reassessment procedure in Morocco
The DGI must state the grounds for the adjustments and allow the taxpayer to respond before the tax is finally assessed.
tax audit of accounts in Morocco
The audit covers the returns, accounting records, invoices, contracts, bank records and electronic data for the periods concerned.
review of the overall tax position
The DGI compares an individual’s declared income with their expenditure, assets, acquisitions and lifestyle indicators.
ex officio assessment in Morocco
Ex officio assessment applies in the cases provided for by the CGI when the taxpayer fails to file a return or respond to a duly served formal notice.
four-year tax limitation period in Morocco
Article 232 of the CGI normally establishes the right to reassess until 31 December of the fourth following year, subject to specific regimes.
DGI right to information
The tax authorities may request from persons legally covered the information and documents needed to audit tax returns.

The tax reassessment procedure in Morocco allows the General Directorate of Taxes (DGI) to correct a return that it considers incomplete or inaccurate, while allowing the taxpayer to challenge the adjustments. It is based primarily on Articles 210, 212, 219 and 220 of the General Tax Code (CGI), in its consolidated version applicable in 2026. It may concern corporate income tax, personal income tax, VAT, registration duties and several withholding taxes.

In practical terms, Article 210 of the CGI authorises the DGI to audit the returns, instruments and documents used to assess tax. The tax authorities use accounting records, invoices, lawfully obtained bank statements, electronic returns, customs data and information received from third parties. The audit may take the form of a tax audit of accounts, a review of an individual’s overall tax position or a desk audit conducted by the tax department.

A distinction must be made between the adversarial procedure and ex officio assessment. Under the former, Article 220 requires the inspector to notify the taxpayer of the grounds and allow thirty days for a response. Ex officio assessment, provided for in particular by Articles 228 et seq., depending on the breach concerned, may follow a failure to file a return or to produce the accounting records after a duly served formal notice. The stages, safeguards and access to the tax commissions are not necessarily the same.

The limitation period is often the first point to check. Under Article 232 of the CGI, the right to reassess may generally be exercised until 31 December of the fourth year following the year for which the tax is due. The calculation nevertheless varies according to the tax, the closing date, the returns filed and any acts capable of interrupting or extending the period. Caution: a general reference to fraud does not automatically give the DGI a uniform ten-year period.

An audit does not necessarily result in all adjustments being upheld. The inspector may withdraw an adjustment after receiving an invoice, a contract or a convincing accounting explanation. In practice, the defence must proceed along two lines: checking whether the DGI complied with the procedure and demonstrating the economic substance of the transactions. A formally valid invoice is not always sufficient to establish that a service was provided, but mere suspicion on the part of the tax authorities is likewise no substitute for precise reasoning.

DGI reassessment notice: checking the letter and its receipt

first DGI notice letter
The first letter sets out the proposed adjustments and starts the period within which the taxpayer may respond.
30-day deadline to respond to a reassessment
Article 220 of the CGI generally allows thirty days after valid receipt of the first notice.
reassessment notice by registered letter
The date and circumstances of delivery must be checked against the notification rules in Article 219 of the CGI.
unclaimed DGI notice
An uncollected or refused item of mail may take effect when the conditions and presumptions provided for in Article 219 are met.
unreasoned tax reassessment
The notice must make it possible to identify the facts, periods, taxes, method and adjusted amounts.
procedural defect in a tax audit
The taxpayer must establish which statutory safeguard was breached and the effect of that irregularity on the audit.

The first letter initiates the adversarial tax reassessment procedure. Under Article 220 of the CGI, it must set out the nature, grounds and detailed amount of the proposed adjustments. For a business, the reader must be able to identify the financial year, tax, accounting entry or transaction concerned and the calculation method. A general statement such as “unsupported expenses,” without an usable breakdown or explanation of the alleged irregularities, may be challenged for insufficient reasoning.

The decisive date is neither the date printed on the letter nor the date on which it was sent. The period begins after notice has been validly served in accordance with Article 219 of the CGI. The address used, the capacity of the person who received the item, the date of first attempted delivery and the statements on the acknowledgement of receipt must be checked. Failing to collect the mail does not necessarily protect the taxpayer: depending on the circumstances, a refused or unclaimed item may be deemed validly served.

Upon receipt, retain the complete letter, its appendices, the envelope and the acknowledgement of receipt. Scan these documents and record the deadline in a calendar shared with the accountant or adviser. In practical terms, a meeting announced by the inspector, a telephone call or an informal request for an extension does not stop the thirty-day period. The response must be filed or sent by a method that provides proof of its date and, as far as possible, its contents.

Each adjustment must then be reconciled with the accounting records and the documents audited. Did the inspector reject an expense because there was no invoice, challenge the existence of the supplier, add back a current account balance or reconstruct turnover? The response depends on the precise grounds. An internal table listing the financial year, tax, amount, DGI position, taxpayer’s argument and corresponding appendices prevents contradictions between the first response, the tax commission proceedings and any future court appeal.

Caution is required when alleging procedural defects automatically. A typographical error that does not affect comprehension does not necessarily result in cancellation of the tax. The safeguard breached must be identified: service at an address that cannot legally be asserted against the taxpayer, bases that cannot be reconstructed, absence of grounds, failure to comply with a mandatory deadline or breach of audit safeguards. The argument must be raised promptly, without abandoning the defence on the merits if the court ultimately finds that the irregularity is not material.

Lawyers at your service

Tax Law lawyers in Morocco

Verified profiles, members of Moroccan bar associations — call or message them directly from their page

Mohamed Adam Trabelsi
3 years of experience

Mohamed Adam Trabelsi

Cabinet Me. Mohamed Adam Trabelsi•Rabat

Maître Mohamed Adam TRABELSI, lawyer at the Rabat Bar. He practises mainly in business law, company law, tax law as well as in mergers and acquisitions transactions. Holder of several specialised diplomas in Business Law and Tax Law, he has a multidisciplinary background enabling him to grasp the legal issues facing companies in their tax, financial and strategic dimensions. He assists Moroccan and international clients in structuring their activities, securing their transactions and preventing legal and tax risks. His practice covers both advisory work and contract drafting as well as assistance in the context of investment operations, restructurings and business litigation. His approach is based on a concrete understanding of the economic stakes of each case, a close relationship with clients and the search for legally secure, pragmatic solutions tailored to their objectives.

Business LawTax LawIntellectual Property+10
French · English · Arabic · +1
Direct contact only
Oussama Razine
6 years of experience

Oussama Razine

Cabinet Me. Oussama Razine•Casablanca

Me. RAZINE OUSSAMA, lawyer at the Casablanca Bar and Doctor of Business Law and Arbitration.

Business LawReal Estate LawTax Law+12
French · English · Arabic
Direct contact only
Yasmina SAIDI
5 years of experience

Yasmina SAIDI

Cabinet Me. Yasmina SAIDI•Fes

A lawyer and Doctor of Business Law, I place at the service of a clientele - made up of individuals, executives and companies - in-depth legal expertise and a strategic vision of economic issues. My practice covers all dimensions of business law, including commercial law, the law of companies in difficulty, financial law, tax law, employment law, civil law, real property law, [•••] etc., as well as business criminal law. I act both in advisory and litigation matters, assisting my clients in structuring, securing and optimising their most sensitive and complex transactions. My involvement follows a logic of anticipating risks, mastering regulatory constraints and creating lasting legal value, as long as it remains possible to prevent and avoid the risk. Should it occur and produce its consequences, I intervene to manage and limit the legal impacts, ensuring optimal protection of my clients' interests. I make a point of providing tailor-made support, based on confidentiality, responsiveness and a fine understanding of my clients' strategic objectives. With a high level of exigency, sharp expertise and rigorous commitment, I strive to establish relationships of trust, by providing legal solutions that match the ambitions and requirements of the clients I assist.

Business LawLabor LawTax Law+15
French · Arabic · English
Online booking · no slot in the next 14 daysBook by phone or WhatsApp.

Taxpayer rights during a tax audit in 2026

DGI audit notice fifteen days
Article 212 of the CGI requires notice to be served at least fifteen days before the date set for the audit to begin.
Morocco audited taxpayer charter
The charter sets out the audit safeguards and must be provided under the conditions prescribed by the CGI.
right to assistance during a tax audit
The taxpayer may be assisted by a lawyer, chartered accountant or other qualified adviser.
tax audit duration for Moroccan SMEs
An on-site audit is normally limited to three months when declared turnover excluding VAT does not exceed 50 million dirhams.
tax audit duration for large companies
The maximum period is generally six months when declared turnover excluding VAT exceeds 50 million dirhams.
DGI rejection of accounting records
The tax authorities must establish the alleged serious irregularities and explain the method used to reconstruct the tax bases.

Before a tax audit of accounts, Article 212 of the CGI requires notice to be served at least fifteen days before the announced start date of the audit. The notice must identify the relevant period and taxes. The audited taxpayer charter must also be provided in accordance with the statutory framework. If either safeguard is missing, retain the available evidence: envelope, acknowledgement of receipt, email, official report and document provided during the first visit.

The taxpayer may be assisted by an adviser of their choice. Depending on the case, the lawyer reviews the procedure and legal characterisations, while the chartered accountant analyses the entries, inventories and reconstruction methods. The company director nevertheless remains essential. They must explain how the business operates, its invoicing processes, unusual payments, transactions with shareholders and relationships with suppliers. A technically correct defence that is inconsistent with the facts observed weakens the case.

The duration of the on-site audit is governed by Article 212 of the CGI. It is normally limited to three months when declared turnover excluding VAT is less than or equal to 50 million dirhams, and to six months above that threshold. Certain statutorily prescribed suspension periods are not counted in the same way. In practice, a dated record should be kept of visits, document requests, file submissions, interruptions and resumptions of the audit.

The DGI may not freely restart an audit concerning the same taxes and the same period. This safeguard does not, however, prohibit every subsequent action. The tax authorities may exercise their right to information, use information received from a third party, or audit another tax, another period or a separate transaction. To determine whether there has been an unlawful second audit, the practitioner examines the true nature of the requests and not merely the title given to them by the department.

Properly maintained accounting records have evidential value, but they are not beyond challenge. Article 213 of the CGI authorises the tax authorities to disregard them when they identify the serious irregularities provided for by the text and then to reconstruct the taxable bases. The notice must set out the irregularities and the method adopted. The taxpayer may challenge the sample, margin coefficients, duplicate entries, inventory, losses, returns and any comparison that does not reflect the actual conditions of their business.

Tax reassessment deadlines and CRRF jurisdiction

30 days after the first DGI notice
The taxpayer must respond within thirty days following valid receipt of the first notice.
60 days for the second DGI notice
The tax authorities generally have sixty days after receiving the observations to notify their reasoned response.
30 days to appeal to the tax commission
An appeal against the bases maintained must normally be lodged within thirty days of the second notice.
Morocco Regional Tax Appeals Commission
The CRRF is currently governed by Article 225 bis of the CGI, introduced by Finance Law No. 50-21 for 2022.
60 days to appeal to the administrative court
Article 242 of the CGI provides for a court appeal within sixty days following notification of the commission’s decision.
tax commission deadline exceeded
Failure to issue a decision within the statutory period may provide access to the court under the conditions prescribed by the CGI.

After the first notice, Article 220 of the CGI allows the taxpayer thirty days to communicate their acceptance or observations. The period begins upon valid receipt, assessed in accordance with Article 219. When the final day raises an issue because it falls on a public holiday or non-working day, the calculation must be checked with the department and the adviser. As a precaution, do not wait until the day before the deadline: file the response several days in advance and obtain a dated receipt.

When the taxpayer responds in time and the inspector rejects all or part of the observations, the DGI sends a second reasoned notice within the period prescribed by Article 220. The sixty days frequently cited here correspond to the period allowed to the tax authorities after receipt of the response. They do not constitute a new general sixty-day period granted to the taxpayer. The second letter must explain the bases maintained and indicate the appeal route before the competent commission.

The operational timetable for the adversarial procedure is as follows. <table><thead><tr><th>Stage</th><th>Deadline</th><th>Legal provision</th></tr></thead><tbody><tr><td>Response to the first notice</td><td>30 days</td><td>Article 220 CGI</td></tr><tr><td>Second DGI notice</td><td>60 days</td><td>Article 220 CGI</td></tr><tr><td>Referral to the specified commission</td><td>30 days</td><td>Article 220 CGI</td></tr><tr><td>Appeal against the commission’s decision</td><td>60 days</td><td>Article 242 CGI</td></tr></tbody></table> Each period begins with the event prescribed by the relevant provision; this table therefore does not replace verification of service.

The Regional Tax Appeals Commission (CRRF) is indeed governed, in the consolidated version of the CGI applicable in 2026, by Article 225 bis. This framework was introduced by Article 6 of Finance Law No. 50-21 for financial year 2022, promulgated by Dahir No. 1-21-115 of 10 December 2021. The CRRF did not entirely replace the Local Tax Commission (CLT): it removed some cases from its jurisdiction, including certain tax audits of accounts below the statutory turnover threshold and disputes concerning income and profits from movable capital.

The allocation of jurisdiction between Article 225 for the CLT, Article 225 bis for the CRRF and Article 226 for the National Tax Appeals Commission (CNRF) must be checked in the consolidated CGI applicable on the appeal date. The reference threshold used for certain audits is 10 million dirhams in declared turnover for each financial year audited, with national jurisdiction above that threshold or for categories specifically assigned to the CNRF. For cases at the threshold or involving several financial years, check the second notice and request proof of transmission from the registry of the competent tax commission.

How to respond to a tax reassessment notice

DGI tax reassessment response template
The response must identify the audit, address each adjustment separately, and refer to numbered exhibits.
limitation period for tax reassessment in Morocco
A plea based on Article 232 must specify the tax, fiscal year, deadline, and any acts interrupting the limitation period.
challenging expenses disallowed by the DGI
The taxpayer must establish that the transaction was genuine, served a business purpose, was recorded in the accounts, and was paid.
challenging reconstructed turnover
The method, coefficients, inventories, losses, returns, and comparative data may be disputed.
documents for a tax audit response
Returns, invoices, contracts, bank records, inventories, and proof of payment must be organised by head of adjustment.
proof of filing a response with the DGI
A receipt or complete postal evidence establishes that the observations were submitted within the time limit.

The response begins with the taxpayer’s tax identification details, the notice number, its date of receipt, the fiscal years audited, and the taxes concerned. It then specifies whether the adjustments are rejected in full or only in part. Each head of adjustment must receive a separate response setting out the facts, the applicable tax rule, the proposed calculation, and the corresponding supporting documents. Merely writing “I dispute the reassessment” does not enable either the inspector or the future commission to understand the position being defended.

Procedural arguments are generally presented first. They may concern the limitation period under Article 232, the audit notice, the duration of the audit, the statement of reasons in the letter, or service within the meaning of Article 219. Each argument must include dates and evidence. Even where a defect appears decisive, address the merits in the alternative. If the commission or court dismisses the procedural irregularity, the case will thus retain an economic and accounting defence.

For a disallowed expense, provide the contract, invoice, proof of delivery or performance, payment, and accounting entry. For reconstructed turnover, check the quantities, margins, losses, returns, inventories, and periods used. Where undeclared income is attributed to an individual, explain the source of transfers, loans, repayments, disposals, or family transfers. The documents must be dated and consistent with both the tax returns and the bank statements.

The file usually includes the notice, its appendices, proof of receipt, tax returns, general ledgers, invoices, contracts, bank statements, inventories, and relevant correspondence. Do not send hundreds of unorganised pages. Prepare a schedule of exhibits, number the documents, and cite their number in each argument. A document without an explanation may not be used effectively; conversely, a precise explanation without supporting evidence remains easy for the tax authorities to challenge.

The response must be signed by the taxpayer or by a representative holding an appropriate power of attorney. It may be filed against a receipt with the designated department or sent by a method that provides proof of the date and receipt. Keep a strictly identical copy. If a document is missing, explain why, state what steps have been taken, and make the necessary reservations. Never assume that oral permission to submit it later extends the time limit under Article 220.

Tax appeals before the CLT, CRRF, and CNRF

Local Taxation Commission in Morocco
The CLT examines disputes that Article 225 of the CGI retains within its subject-matter and territorial jurisdiction.
Regional Tax Appeals Commission in Morocco
The CRRF under Article 225 bis directly handles the categories of cases assigned to it by law.
National Tax Appeals Commission
The CNRF rules on cases falling directly under Article 226 of the CGI and sits at the national level.
referral to a tax commission within 30 days
The appeal must be filed within thirty days of the second notice, with proof of delivery.
DGI tax commission hearing
The taxpayer may defend the case using quantified explanations and supporting documents, with the assistance of an adviser.
questions of law before a tax commission
The commissions do not rule on matters that the CGI classifies as involving the interpretation of legislative or regulatory provisions.

Tax commissions are specialised administrative bodies, not courts. The CLT is governed by Article 225 of the CGI, the CRRF by Article 225 bis, and the CNRF by Article 226. Since the reform introduced by Finance Law No. 50-21 for 2022, the CLT is no longer a mandatory stage in every audit. Jurisdiction depends on the subject matter, the type of audit, the turnover declared, and the categories expressly assigned to the CNRF.

In practice, the CLT retains, in particular, certain disputes relating to professional income subject to regimes specified by law, income and profits from real property, and registration duties. The CRRF examines, in particular, appeals relating to income and profits from securities and certain accounting audits involving taxpayers below the statutory threshold. The CNRF directly hears major audits, certain specific transactions, and the review of the taxpayer’s overall tax position provided for in Article 216.

The referral must cover all adjustments that remain disputed. It states the references of the second notice, the tax bases maintained, the grounds for disagreement, and the amounts requested. Attach both notices, the previous responses, the adviser’s power of attorney, and a schedule of exhibits. Filing must take place within thirty days under Article 220. Obtain dated proof and immediately verify any objection raised by the department regarding the recipient body or territorial jurisdiction.

The commissions primarily assess questions of fact: whether a service was actually provided, the value of an asset, the evidential reliability of the accounts, the margin coefficient, or the reconstruction method. They may not decide questions that the CGI reserves for the interpretation of legislative and regulatory provisions. The CNRF is therefore not a general appellate body for decisions of the CLT or CRRF. Depending on the case, the legal issue must be brought before the Administrative Court after the tax assessment has been issued.

The taxpayer may submit observations and be assisted or represented in accordance with the applicable rules. A short brief, a quantified table, and a few decisive documents are often more useful than a disorganised file. The decision must state reasons and be served. If it upholds the adjustments, or if the commission fails to rule within the statutory time limit, Article 242 may allow judicial proceedings to be brought. The date on which the decision was served must then be kept just as carefully as the dates of the DGI’s letters.

Administrative Court, stay of payment, and appeal costs

Administrative Court tax reassessment proceedings
The taxpayer may seek the cancellation or reduction of tax assessments issued following the tax procedure.
mandatory lawyer before Morocco’s Administrative Court
In principle, the application must be filed by a lawyer registered with a Moroccan bar association, pursuant to Article 3 of Law No. 41-90.
administrative stay of tax debt recovery
Articles 117 and 118 of the Collection Code provide for an application to the public accountant, with partial payment and guarantees.
judicial stay under Article 243 of the CGI
Article 243 of the CGI provides for a separate application to the court in proceedings governed by that provision.
payment of 20% of disputed tax debt
The administrative mechanism under Article 117 requires, in particular, payment of at least 20% of the disputed amounts.
tax lawyer fees in Morocco
Fees charged in 2025-2026 vary according to the amount at stake, the supporting documents, and the number of appeals, with no mandatory national fee scale.

Proceedings under Article 242 of the CGI are brought before the Administrative Court having territorial jurisdiction, in accordance with Law No. 41-90 establishing the Administrative Courts. The application may seek full cancellation, a reduction of the tax, or the consequences of a material procedural irregularity. The time limit is sixty days after service of the decision of the competent commission. The CGI also allows judicial proceedings in certain circumstances where the commission has not ruled within the time allotted to it.

Before the Administrative Court, the application must, in principle, be filed by a lawyer registered with a Moroccan bar association, in accordance with Article 3 of Law No. 41-90. The judgment may be appealed before the Administrative Court of Appeal and then challenged before the Court of Cassation. Each stage has its own rules and time limits. The sixty-day time limit provided for in Article 242 must therefore not be applied mechanically to appeals or cassation proceedings.

The administrative stay is governed by Articles 117 and 118 of Law No. 15-97 constituting the Code for the Collection of Public Debts. A taxpayer disputing the debt asks the public accountant to suspend recovery proceedings in respect of the disputed portion. This mechanism requires, in particular, payment of at least 20% of the disputed amounts and the provision of acceptable guarantees for the balance. The application must identify the tax assessments, the appeal filed, and the guarantees offered; filing it does not, by itself, constitute acceptance.

The judicial stay under Article 243 of the CGI is a separate mechanism, requested from the court in proceedings covered by that provision. It does not render Articles 117 and 118 inapplicable and does not make a tax appeal automatically suspensive. The court assesses the application in light of the statutory conditions, the grounds relied upon, and the evidence produced. In practical terms, a prompt decision is needed on whether to apply to the public accountant, petition the court, or coordinate both steps without submitting contradictory applications.

COST NOTE 2025-2026 — The following ranges are based on professional practice and not on an official fee scale. Accounting or tax preparation for a substantial case often costs between 15,000 and 50,000 dirhams; lawyers’ fees for complex proceedings frequently range from 20,000 to 100,000 dirhams, and sometimes more. Depending on the case, disbursements, translations, expert assessments, and bank guarantees must be added. Court registry fees and the costs of required procedural documents should be checked with the court registry and the lawyer.

Common errors, special cases, and the tax lawyer’s role

failure to respond to a reassessment notice
Silence may allow the tax assessment to be issued and result in the loss of the right to refer the matter to the commission under the adversarial procedure.
oral objection to a DGI inspector
A conversation, meeting, or promise of an appointment does not replace a written response filed within the time limit.
partial acceptance of a tax reassessment
The response must identify the amounts accepted and maintain express reservations regarding each disputed adjustment.
tax lawyer during a DGI audit
The lawyer reviews the procedure, prepares the legal arguments, and organises administrative and judicial appeals.
chartered accountant and tax reassessment
The chartered accountant analyses the entries, gathers supporting documents, and tests the DGI’s calculations.
tax residence in Morocco for MREs
Article 23 of the CGI determines tax residence based, in particular, on the permanent home, the centre of economic interests, and the duration of stay.

The first error is failing to respond because oral negotiations are supposedly underway. Silence upon expiry of the time limit under Article 220 allows the tax assessments to be issued on the notified bases and may bar referral to the commission. A subsequent administrative claim may remain possible in certain situations provided for by the CGI, but it does not automatically restore the safeguards that were lost. Any discussion with the inspector must therefore be accompanied by a written submission filed in the proper form and within the applicable time limits.

The second error is defending only the procedure or only the figures. A serious defect in service may affect the reassessment, but it will be dismissed if service is found to have been valid. Conversely, producing invoices without challenging a reconstruction method leaves certain heads of adjustment unresolved. A complete defence assesses the notices against Article 219, the audit against Articles 212 and 213, the limitation period against Article 232, and then each transaction against the applicable rules on deductibility and evidence.

The third error is changing the explanation during successive appeals. An amount described as a shareholder’s loan in the first response cannot become a customer advance before the commission without a precise justification. The contracts, accounting entries, returns, and bank transactions must all tell the same story. Before filing, the lawyer and chartered accountant compare the legal chronology with the accounting data. This cross-review prevents a legally persuasive argument from relying on an incorrect amount or date.

For a Moroccan residing abroad, Article 23 of the CGI must be examined: it refers, in particular, to a permanent home, the centre of economic interests, and presence in Morocco exceeding 183 days during any 365-day period. A tax treaty may resolve dual residence. For example, the Franco-Moroccan Tax Convention signed on 29 May 1970 applies its own treaty criteria; for another country, the treaty actually in force must be consulted rather than applying this convention by analogy.

A tax lawyer can usefully become involved as soon as the audit notice is issued where numerous fiscal years are involved, the accounts are at risk of being rejected, or the case includes international financial flows. The lawyer reviews the notices, preserves the necessary reservations, and prepares the proceedings before the commission and the court, as well as stay applications. The chartered accountant extracts the entries, tests the calculations, and explains the accounting methods. To assess an appropriate strategy without presuming the outcome, the taxpayer may consult a tax lawyer on AvocatLib.

Need a Tax Law lawyer?

Browse verified profiles near you

Browse the directory

Frequently Asked Questions

What is the deadline for responding to a tax reassessment notice in Morocco?
As a rule, the taxpayer has thirty days from due receipt of the first notice, in accordance with Article 220 of the General Tax Code (CGI). The date shown on the letter is not sufficient: service must be verified under Article 219 of the CGI. A discussion with the tax inspector or an informal request for an extension does not suspend this deadline.
What happens if I do not respond to the DGI’s letter?
Failure to respond allows the DGI to assess the tax on the notified bases and may result in loss of access to the tax commission under the adversarial procedure provided for in Article 220 of the CGI. A telephone conversation or meeting is not a substitute for a written response. Even if all supporting documents have not yet been gathered, you must respond within the deadline, set out your objections and retain proof of filing.
How do I refer a case to the Local Taxation Commission in Morocco?
The referral must normally be made within thirty days following receipt of the second notice provided for in Article 220 of the CGI. Since the reform introduced by Finance Law No. 50-21 for 2022, certain cases no longer fall within the jurisdiction of the CLT but instead come under the CRRF governed by Article 225 bis, or directly under the CNRF referred to in Article 226. You must follow the body specified in the notice while legally verifying that it has jurisdiction.
What is the difference between the CLT, CRRF and CNRF?
The CLT, governed by Article 225 of the CGI, retains the categories of disputes assigned to it by that provision, including certain matters of a local nature. The CRRF under Article 225 bis deals in particular with income and profits from movable capital, as well as certain accounting audits below the statutory turnover threshold. The CNRF under Article 226 directly hears cases reserved for it, including certain major audits and reviews of the taxpayer’s overall tax position; these commissions do not constitute three successive levels of appeal.
What safeguards do I have during an accounting audit?
Article 212 of the CGI notably requires an audit notice to be served at least fifteen days before the audit begins and recognises the right to be assisted by an adviser. An on-site audit is normally limited to three months where the declared turnover excluding VAT does not exceed 50 million dirhams, and to six months above that threshold. However, certain periods excluded by law must be deducted from this calculation.
Can a tax reassessment be challenged before the Administrative Court?
Yes. Article 242 of the CGI allows the Administrative Court to be petitioned within sixty days following notice of the decision of the competent commission, as well as in certain circumstances where the commission has not ruled within its statutory time limit. In principle, the application must be filed by a lawyer admitted to a Moroccan bar, in accordance with Article 3 of Law No. 41-90.
What arguments can be used against a DGI tax reassessment?
Procedural arguments may concern the limitation period under Article 232 of the CGI, service under Article 219, the duration of the audit or insufficient reasoning. Substantive arguments often concern the actual existence of expenses, the origin of bank transfers, the value of an asset or the method used to reconstruct turnover. Each argument must be linked to a supporting document, an accounting entry and, where necessary, an alternative calculation.
Can the DGI audit more than four years?
Article 232 of the CGI generally provides for a right of reassessment until 31 December of the fourth year following the year for which the tax is due. Special rules, loss-making returns, interruptive acts or certain transactions may alter this calculation. There is no general rule automatically allowing a ten-year audit period whenever the tax authorities allege fraud.
How much does it cost to appeal a tax reassessment in Morocco?
Tax commissions do not normally charge registry fees. Based on professional practices observed in 2025-2026, and in the absence of an official fee scale, accounting or tax assistance for a substantial case often costs between 15,000 and 50,000 dirhams, while court proceedings cost between 20,000 and 100,000 dirhams, and sometimes more. Bank guarantees, expert assessments, disbursements and successive appeals may entail additional costs.
How can payment be suspended during a tax appeal?
Two mechanisms must be distinguished. Articles 117 and 118 of Law No. 15-97 establishing the Public Debt Collection Code provide for an administrative stay, notably requiring payment of at least 20% of the disputed amounts and the provision of guarantees for the balance. Article 243 of the CGI also allows an application to be made to the judge for a stay in proceedings falling within the scope of that provision; this judicial stay is neither automatic nor the same as the application submitted to the public accountant.

Have your tax notice reviewed

A tax lawyer can review deadlines, procedural compliance, collection measures and supporting documents before you respond to the DGI or file an appeal.

Consult a tax lawyer on AvocatLib