On 14 December 2018, the Moroccan General Directorate of Taxation released guidelines detailing the rules to conclude an Advance Pricing Agreement (APA) for transfer pricing purposes. The guidelines clarify the rules on:
- The initial APA application, including that:
- Applications may only be made in respect of cross-border operations;
- Applications must be made at least 6 months before the beginning of the first financial year to be covered by the APA;
- The initial procedure involves the holdin…