Morocco published Ministerial Decree No. 423.21 in the Official Gazette on 18 March 2021, which reduces the maximum interest rate for loans granted by direct shareholders from 2.23% for 2020 to 1.63% for 2021. Interest expense on loans exceeding that rate is generally non-deductible.
In addition to the interest rate limitation, Morocco also disallows the deduction of interest expense for loans from shareholders if the capital of a company has not been fully paid up and interest expense on t…