Definition
What this is about
The article governing the question is headed « Place of taxation » : « Tax is assessed at the place of the taxpayer's tax domicile or of their principal place of business » art. 72 CGI. It immediately draws the consequence : « A taxpayer who does not have their tax domicile in Morocco is required to elect one in Morocco. »
The obligation carries no condition : it applies to the taxpayer, without distinguishing according to the nature or amount of their Moroccan income. The same article organises the updating of the address : « Any change of tax domicile or of the place of the principal place of business must be reported to the tax administration by registered letter with acknowledgement of receipt, by delivery against receipt, or by filing a return on or in accordance with a model form established by the administration, within thirty (30) days following the date of the change. »
Then comes the sentence that gives this page its subject : « Failing that, the taxpayer is notified and taxed at the last known address. » Not a financial penalty, but a rule of attribution : the administration writes where it last wrote, and the procedure takes its course.
Scope
Who is concerned
- Any individual without a tax domicile in Morocco within the meaning of article 23-II, liable in respect of their Moroccan-source income and gains art. 23-I-2°.
- Non-resident owners of property located in Morocco, for rental income as well as for property capital gains.
- Persons who retain shareholdings, accounts or other sources of income in Morocco, and those whose file remains open to audit.
- Persons who have already left without reporting a change of address : for them, the « last known address » is a Moroccan address they no longer occupy.
The obligation stands alone : it is not to be confused with the departure return, which is a one-off, prior filing, nor with the annual global income return, which must state « the surname, forenames and address of the taxpayer's tax domicile » art. 82-I.
Applicable rules
Why an address amounts to notification
The reach of the election is measured by the article governing the forms of notification. Notification « is made to the address indicated by the taxpayer in their returns, deeds or correspondence communicated to the tax inspector of their place of taxation », by registered letter with acknowledgement of receipt, by personal delivery — sworn officers, court registry officers, bailiffs — « or through administrative channels » art. 219-I CGI.
The decisive point is the fate of the letter that does not arrive. The document is deemed validly notified « if it could not be delivered to the taxpayer at the address they communicated to the tax inspector » and it « was returned marked unclaimed, change of address, unknown or incomplete address, premises closed or taxpayer unknown at the stated address ». In such cases, « the letter is deemed to have been delivered upon expiry of a period of ten (10) days following the date on which the failure of delivery was recorded » art. 219-I-2°.
Failed delivery therefore suspends nothing : it triggers a ten-day period at the end of which the notification produces its full effects, and the periods for reply, for adjustment, for automatic assessment and then for claims all run from that point. An assessment thus becomes final against a person who is unaware of its existence.
The code provides a second route : « in addition to the forms of notification referred to in paragraph I », notification « may be made by electronic means […] to the electronic address referred to in article 145-X », communicated by the taxpayer, and it « produces the same legal effects » art. 219-II. Article 145-X states that « taxpayers subject to the taxes, duties and levies in force must hold an electronic address of their choice ».
It must be said here what the code does not say. It requires the holding of an electronic address and makes notification to that address fully effective, but it lays down no procedure for communicating or updating it. Nor does it say what an elected domicile must be, who may host it, or what form the election takes : article 72 governs only the notification of the change. Yet assessment by way of tax roll is attached to the « tax domicile elected in Morocco » art. 175-I : the code presupposes the election without organising the arrangements for it.
Deadlines and limitation
The timetable
- Within 30 days of the change
Any change of tax domicile or of the place of the principal place of business must be reported, through one of the three channels of article 72 art. 72.
- At any time
Notification is validly made to the address indicated by the taxpayer ; failing that, to the last known address art. 72 and 219-I.
- 10 days after failed delivery
A letter returned for change of address, unknown address, closed premises or unknown taxpayer is deemed delivered, and the procedural periods run from that date art. 219-I-2°.
- 6 months
Claim period : six months following the month of collection, or following the expiry of the prescribed periods in the case of spontaneous payment art. 235.
- Until 31 December of the 4th year
Ordinary reassessment period art. 232-I, extended for undeclared years to a limit of ten years art. 232-VIII-15°.
These periods are not suspended by the taxpayer's ignorance : a person who has left without an up-to-date Moroccan address may discover, years later, a final assessment and expired remedies.
Documents and supporting evidence
The elements of the file
- Tax identification details : tax identifier, national identity card or residence card number, existing assessment references.
- The history of declared addresses : those appearing on earlier returns, deeds and correspondence, which determine the « last known address ».
- The elected domicile in Morocco : documents establishing the reality of the address chosen and the consent of the person hosting it.
- The electronic address : which article 145-X requires to be held and at which notification produces the same legal effects art. 219-II.
- Moroccan income retained : property, shareholdings, accounts and other sources grounding the continuing liability.
This list is indicative ; the exact composition depends on the situation.
Points requiring care
What can cause a file to fail
- Believing that departure closes the file : the obligation to elect a domicile falls precisely on the person who no longer has a Moroccan tax domicile art. 72.
- Leaving an abandoned address in place : it remains the « last known address » and grounds valid notifications.
- Counting on the letter being returned : the mention « change of address » or « unknown address » does not defeat the notification ; it fixes its date, ten days later art. 219-I-2°.
- Discovering the assessment too late : the six-month claim period runs from the date of collection, not from actual knowledge art. 235.
- Believing that a claim suspends collection : it « does not prevent the immediate collection of the sums due » nor the commencement of enforced collection art. 235.
It is frequently read that a declaration of transfer of tax domicile would serve as a formality for exiting the Moroccan tax territory. The code does provide for notification of a change within thirty days, possibly « on or in accordance with a model form established by the administration » art. 72, but it names no form and does not deal with transfer abroad. Only the obligation and its consequence are certain.
We take the file in hand
Aurion keeps up to date, with the inspector of the place of taxation, the address appearing on the taxpayer's returns and correspondence, so that notifications actually reach them. The firm reconstructs situations already notified to an abandoned address and pursues the remedies still open. It then provides ongoing monitoring of the file. Responsibility for the outcome remains ours.
Secure my tax domicile- General Tax Code, 2026 edition — art. 23 (I-2° and II), 72, 82-I, 85, 145-X, 175-I, 219 (I, I-2° and II), 228, 232 (I and VIII-15°), 235
- Finance Act no. 68-17 (2018) — paragraphs I and II of article 219 ; obligation to hold an electronic address, article 145-X
- Finance Act no. 60-24 (2025) — notification by electronic means and the legal effects attached to it, article 219-II
- Finance Acts no. 60-24 and no. 50-25 (2025 and 2026) — wording of article 145-X in force
- Finance Act no. 70-15 (2016) — three-month period of article 235
Page updated as at 20 August 2026. The amounts and time limits cited are those of the General Tax Code, 2026 edition.
