Transfer Pricing Analysis in the Moroccan Context

Abstract

This article investigates the issue of transfer pricing in the Moroccan context, emphasizing its growing significance in the governance of multinational taxation. As an emerging economy striving to balance tax attractiveness, anti-avoidance efforts, and alignment with international norms—particularly OECD guidelines—Morocco faces several structural challenges. These include regulatory ambiguity, limited jurisprudence, and a persistent climate of distrust between tax authorities and multinational enterprises.

Drawing on a narrative and critical literature review, and grounded in the theoretical frameworks of transaction cost economics and agency theory, this paper provides a dual analysis of Moroccan tax provisions and the arm’s length principle. It synthesizes key empirical studies that highlight the determinants of compliance, transparency, and fiscal cooperation.

The objective is to identify the institutional, legal, and behavioral barriers to building a sustainable climate of trust and to propose realistic reforms aimed at strengthening the documentation framework and fostering constructive engagement between stakeholders in the area of transfer pricing.

JEL Classification : F23, G28, H2, H3.

Type du papier : Theoretical Research.