Morocco published Ministerial Decree No. 408.23 in the Official Gazette on 23 February 2023, which sets the maximum interest rate for loans granted by direct shareholders to 1.89% for 2023. 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 the amount of a loan …