Finance

A $5,000 flat tax costs a Moroccan company €107,130 in France

27 September 2026·2 min read

SARL Sauret Consultants Holding Offshore received French dividends over three years. France withheld a total of €107,130. The tax treaty does not allow exemption because the dividends were not taxable in Morocco, as ruled by the Paris Court of Appeal.

A Moroccan company faced with French withholding tax on dividends

Sauret Consultants Holding Offshore SARL received dividends paid by a French company for three years. France withheld €38,513 in 2019, €43,754 in 2020 and €24,863 in 2021, making a total of €107,130 in withholding tax.

The dividends received from France could not be considered taxable in Morocco within the meaning of the tax treaty. The condition conferring entitlement to exemption from French withholding tax was therefore not met.

Tax form 5000-FR produced by the company only attested to its Moroccan tax residence. The judges considered that this document did not demonstrate that the dividends in question actually formed part of the base of a Moroccan tax covered by the treaty.

In its judgment of 30 April 2026, the Paris Administrative Court of Appeal upheld the validity of the withholding taxes applied by the French tax authorities. The decision validates the reassessment for the three financial years concerned.

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