The 2026 tax reform has intensified scrutiny on free zone companies. The corporate tax convergence initiated by Framework Law 69-19 is accompanied by increased DGI verification, particularly to ensure that declared benefits are properly justified. Here is how to anticipate an audit and protect your business.
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Why Free Zone Companies Are Under Scrutiny in 2026
- EU pressure: Morocco has been kept under monitoring regarding the list of non-cooperative jurisdictions. The DGI must demonstrate that free zone tax benefits correspond to real economic activity (“economic substance”).
- IS convergence: the gradual transition to the 20% rate creates gray areas on transitional periods, generating errors and reassessments.
- Digitalization of controls: since 2024, the DGI automatically cross-references IS/IR declarations with CNSS, VAT, and Foreign Exchange Office data.
The 5 Triggers That Initiate a Tax Audit
| Warning Signal | Associated Risk |
|---|---|
| Declared turnover significantly lower than banking flows | Presumption of concealed income |
| Abnormally high deductible VAT relative to turnover | False invoices or fictitious purchases |
| CNSS payroll inconsistent with declared activity | Undeclared or fictitious employment |
| Dividend distributions without withholding tax | WHT recovery + 15% penalties |
| Absence of real economic substance in the free zone | Revocation of IS exemption |
Documents to Keep Ready at All Times
A tax audit can be triggered at any time within a 4-year statute of limitations. Essential documents include:
- General ledger compliant with CGNC (Moroccan General Accounting Standards)
- FEC (Fichier des Écritures Comptables): mandatory since 2021 for IS-liable companies
- All purchase and sales invoices, chronologically filed, stamped and signed
- Commercial contracts with clients and suppliers, especially intra-group agreements
- Foreign exchange declarations and Office des Changes supporting documents for each transfer
Need advice on this topic? Cabinet Dami & Associés, chartered accountants with offices in Tangier and Casablanca, will reply within 24 hours.
Audit Duration and Proceedings
| Criterion | SMEs | Large companies (turnover > MAD 50M) |
|---|---|---|
| Maximum on-site audit duration | 6 months | 12 months |
| Response deadline for reassessments | 30 days | 30 days |
| Appeal to Local Tax Commission (CLT) | Yes | Yes |
| Appeal to National Tax Appeal Commission (CNRF) | Yes | Yes |
Your Rights When Facing the DGI
- Right to assistance: you can be represented by your chartered accountant or tax advisor at all stages.
- Right of reply: 30 days to contest notified reassessments, with possible extension upon reasoned request.
- Right of appeal: CLT then CNRF before any judicial appeal. These bodies are free and suspend collection during their proceedings.
- Penalty limitation right: in case of spontaneous correction before audit, penalties are reduced to 5% instead of 15%.
Our Recommendation: Annual Preventive Audit
At Cabinet Dami Tanger, we offer an annual preventive tax audit specifically designed for free zone companies. In 2026, with tightened controls, this audit has become essential: we verify declaration compliance, CGNC accounting adequacy, and the solidity of your file in case of an unannounced audit. Contact us before the DGI does.
Further reading
Related resources: tax & social advisory, tax litigation, tax and accounting mistakes, reporting obligations.
Official source: General Tax Code (CGI) — Moroccan Tax Authority (DGI).
Information may change under the regulations in force. For advice tailored to your situation, contact Cabinet Dami & Associés.
Further reading
