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🇲🇦 Tax Refunds for Moroccan Workers in Ireland, and the Ireland–Morocco Tax Treaty: Who Taxes Your Salary, Pension and Property

Morocco is one of only six African countries with a tax treaty in force with Ireland, and with direct flights from Dublin to Marrakech, Agadir and Rabat the traffic runs both ways: Moroccans working in Irish kitchens, hotels, hospitals and tech firms, and Irish people buying a riad or planning to retire to the coast. The treaty decides who taxes what in both directions. On the Irish side, payroll never adds the credits you have to ask for, and a second job is where most Moroccan workers lose money.
- The Ireland–Morocco treaty, applied since 1 January 2012, lets Ireland tax your salary for work done here and Morocco tax rent and gains on Moroccan property.
- Ireland gives a credit for that Moroccan tax, Moroccan tax on dividends and interest is capped at 10%, and private pensions go to the country where you live.
- In our example, a chef in Dublin with a second job and a widowed mother in Fès is owed €2,864.40 for 2024.
So an Irish occupational pension can be paid without Irish tax once you're resident in Morocco. Four years are open, and 2022 closes on 31 December 2026. Run your own figures in the tax refund calculator.
Is there a tax treaty between Ireland and Morocco?
- Yes, and it's in force: signed in Rabat on 22 June 2010, it has applied in Ireland since 1 January 2012 for income tax, CGT and corporation tax (S.I. No. 19 of 2011).
- Revenue publishes no synthesised text with the OECD multilateral instrument for Morocco (checked October 2026), so the treaty applies as signed.
- That means no anti-abuse test from the instrument and no 365-day rule for property-rich shares.
- The text. Revenue publishes the convention on its Morocco treaty page; the signing and effective dates are on Revenue's dates of effect table. The convention lists the income levy rather than USC, which replaced it in 2011, but Article 2(4) extends it to identical or substantially similar taxes introduced later.
- One of six in Africa. Ireland's treaties in effect in Africa are with Morocco, Egypt, South Africa, Zambia, Botswana and Ethiopia. Kenya and Ghana have signed treaties that aren't yet in effect; Nigeria, Uganda and Zimbabwe have none. The full list shows every country.
- What a treaty doesn't do. It doesn't create Irish reliefs or replace your Irish return. You still claim credits, declare foreign income and file in Ireland the normal way; the treaty decides which country may tax each item and how the other gives relief.
- What it does for Moroccan citizens in a non-resident year. Revenue gives personal tax credits to non-residents only if they're EU citizens or citizens of a country with a tax treaty (Revenue). Because the Morocco treaty is in force, a Moroccan citizen with Irish income in a year they're not Irish resident gets the full credits if all their income is Irish, otherwise a share in proportion to the part of their total income that's Irish.
Does Morocco still tax you after you move to Ireland?
- It can in the year you move: Morocco taxes residents on worldwide income, and its first residence test is your permanent home (PwC's summary, reviewed April 2026).
- Once the treaty's tie-breaker makes you resident in Ireland, your salary for work done here is taxable only in Ireland (Article 15(1)).
- If it still points to Morocco, as it can in the move year, Ireland taxes the pay for work here and Morocco must deduct the Irish tax (Article 23(1)).
- Morocco's residence tests, in order. Your permanent home; then the centre of your economic interests; then presence in Morocco for more than 183 days in any 365-day period (PwC Morocco, residence). Residents are taxed on worldwide income, non-residents only on Moroccan-source income (PwC Morocco, personal income), at rates from 0% on the first MAD 40,000 to 37% above MAD 180,000.
- The treaty's tie-breaker (Article 4(2)). If both countries treat you as resident, you're resident where you have a permanent home; if you have one in both, where your personal and economic relations are closer; then where you habitually live; then your nationality; then by agreement between Revenue and the Direction Générale des Impôts. A rented or owned home in Ireland, your job here and your family here usually settle it in Ireland's favour, but a house in Morocco that's kept available to you can keep the question open, so keep a record of your days and of where your family and work were.
- Your Irish salary (Article 15). Pay for work done in Ireland is taxable in Ireland. The exception for stays of up to 183 days in any 12-month period works only if your employer isn't resident in Ireland and the pay isn't borne by an Irish branch, which rules out an Irish hospital, hotel or company.
- Irish residence is a day count. 183 days in a tax year, or 280 over this year and last with more than 30 this year (Revenue). In your arrival year you can elect to be resident so that you get a full year's credits; our residence guide explains split-year treatment.
What about a flat in Casablanca, Moroccan savings and dividends?
- Morocco keeps the right to tax rent and gains on Moroccan property, and may tax interest and dividends at no more than 10%.
- If Ireland taxes the same income, because you're Irish-domiciled or bring the money in, Article 23(2) credits the Moroccan tax against the Irish tax.
- Nigerians, Ugandans and Zimbabweans don't get that credit: without a treaty, foreign tax on rent is only a deduction.
| Income from Morocco | Treaty rule | What it means in practice |
|---|---|---|
| Rent from a flat in Casablanca or Tangier | Article 6: Morocco may tax it as the property's country | Morocco taxes gross rent at 10% below MAD 120,000 a year and 15% from MAD 120,000 (PwC). Ireland taxes the net rent too if you're Irish-domiciled, or what you bring in if you're not, with a credit for the Moroccan tax |
| Selling a Moroccan property | Article 13(1): Morocco may tax the gain | Morocco charges 20% of the gain, with a minimum of 3% of the sale price, and exempts a principal residence held for at least six years (PwC). An Irish resident is within Irish CGT (31% for disposals from 7 October 2026) on the gain if Irish-domiciled, or on the gain to the extent the proceeds are brought into Ireland if not, with credit for the Moroccan tax |
| Interest on Moroccan savings | Article 11: Morocco may tax it, but at no more than 10% | Morocco taxes interest received by its own residents at 30% (PwC); if your bank still treats you as Moroccan resident, give it proof of your Irish residence so the treaty's 10% cap applies; the interest is also Irish taxable income, in full if you're Irish-domiciled, when brought in if you're not, with credit for the Moroccan tax actually due under the treaty |
| Dividends from Moroccan companies | Article 10(2): Morocco may tax at no more than 10% for individuals | Morocco's domestic withholding on dividends is 11.25% for 2026 (PwC) and is falling to 10% in 2027 under Morocco's 2023 finance law, so the treaty's 10% cap still saves a little this year; Ireland taxes the dividends with credit for the Moroccan tax |
| Shares in property-rich companies | Article 13(2): treated like the property itself | Morocco may tax gains on shares that derive more than 50% of their value from Moroccan immovable property; there's no 365-day look-back because the multilateral instrument doesn't modify this treaty |
- Domiciled or not. Moving here doesn't by itself make you Irish-domiciled (Revenue, domicile). On the remittance basis you're taxed only on what you bring into Ireland, as money or value, and foreign rent brought in is taxed with no deduction for expenses (Revenue). Our remittance basis guide and foreign rental income guide work through both cases with figures.
- No remittance clause. Unlike the South African treaty, the Moroccan one has no article limiting Morocco's treaty rates to income you bring into Ireland, so the 10% caps apply whether or not the money leaves Morocco.
- Which Irish form. A PAYE worker can declare foreign income on Form 12 if taxable non-PAYE income is €5,000 or less and gross non-PAYE income is €30,000 or less; otherwise it's Form 11. Keep the Moroccan tax receipt or withholding statement: it's the proof for the credit.
- Exchange rates. Revenue's published average annual rates (manual 04-06-12) cover 13 currencies and the dirham isn't one of them, so use the rate you actually received when the money was converted, or a published central bank rate for the year, and keep a note of which you used.
Who taxes your pension if you retire to Morocco, or draw a Moroccan one here?
- Occupational pensions and life annuities for past employment are taxed in the country where you live (Article 18(1)).
- An Irish occupational pension paid to a Morocco resident is taxable only in Morocco, and Revenue can issue a PAYE Exclusion Order so it's paid without Irish tax.
- The State Pension and HSE, teacher's or civil service pensions stay Irish-taxable: social security and government pensions stay with the paying country (Articles 18(4), 19(2)).
The exception for government service pensions: they stay with the paying country unless you're both resident in and a national of the other.
| Pension | Treaty rule | What it means in practice |
|---|---|---|
| Irish occupational pension, or a PRSA or annuity funded from your employment, paid to a resident of Morocco | Article 18(1): taxable only in Morocco | Revenue's manual 42-04-01 says a PAYE Exclusion Order should issue where the treaty gives the pension to the country of residence; the scheme paying the pension applies once you give it proof of your Moroccan tax residence, and Morocco taxes it under its own rules |
| Irish State Pension paid to a resident of Morocco | Article 18(4): social security pensions are taxable only in the paying country, so only in Ireland | The Department of Social Protection pays it without deducting tax, but it stays chargeable to Irish income tax; as a Moroccan citizen you get Irish credits in proportion to your Irish share of total income: with the State Pension as your only income you get the full credits, though on a full-rate pension they may not cover all the tax; but if an Irish occupational pension is also paid to you in Morocco the credits are scaled down and some Irish tax is normally due on the State Pension through a non-resident return. Morocco must give a deduction for any Irish tax (Article 23(1)) |
| Irish public service pension (HSE, teachers, civil and public servants) | Article 19(2)(a): taxable only in Ireland | Stays in Irish PAYE wherever you live, unless you're both resident in Morocco and a Moroccan national (Article 19(2)(b)), in which case Morocco taxes it instead |
| Moroccan private or occupational pension paid to a resident of Ireland | Article 18(1): taxable only in Ireland | Declare it on your Irish return as foreign pension income (on the remittance basis if you're not Irish-domiciled); Morocco shouldn't tax it, so there's normally nothing to credit |
| Moroccan CNSS (social security) pension paid to a resident of Ireland | Article 18(4): taxable only in Morocco | Ireland can't tax it under the treaty; show it on your Irish return as treaty-exempt income and keep the CNSS statement. Article 23(4) would let Ireland take it into account when fixing the rate on your other income, which Irish income tax doesn't do in practice |
The Exclusion Order route is set out in Revenue's manual 42-04-01, section 6.2 for private-sector occupational pensions and 6.3 for public service pensions. Compare the Egyptian treaty, which keeps every Irish pension, private ones included, taxable in Ireland. If you leave Ireland for Morocco part-way through a year, our leaving Ireland guide covers split-year treatment and the refund on the way out.
What are Moroccan workers in Ireland most likely owed?
- The second-job overcharge, the Rent Tax Credit, your job's flat rate expense and, for a widowed parent you support in Morocco, the Dependent Relative Tax Credit.
- If your spouse is still in Morocco with no income, the married credit and band through aggregation relief is the biggest single item.
- Second job and agency shifts. A second employment gets no credits and no standard rate band unless you split them, so it's taxed at 40% from the first euro. If your total income for the year sits inside the 20% band (€42,000 for a single person in 2024, €44,000 in 2025), the extra 20 points come back after the year ends: €8,000 of second-job pay is a €1,600 refund. See tax on a second job.
- Flat rate expenses. Revenue's list gives the hotel industry fixed amounts with no receipts: chef €97, head waiter €127, waiter or waitress €80, hall porter €64, kitchen porter €21, manager €191; bar staff €93; shop assistants €121; hospital doctors €695, pharmacists €400 and nurses €733, €638, €353 or €258 depending on who supplies and launders the uniform. A flat rate expense is a deduction, so €97 is worth €19.40 at 20%, every year for four years.
- Rent Tax Credit. 20% of the rent you paid, capped at €500 for 2022 and 2023 and €1,000 a year from 2024 (double for a jointly assessed couple), never more than your income tax for the year. Our Rent Tax Credit guide covers RTB registration, digs and rent-a-room arrangements.
- Married credit when your spouse is still in Morocco. If you're married and your spouse isn't resident in Ireland, payroll treats you as single. After the year ends you can ask for aggregation relief: with no income on their side you get the full married credit (€3,750 instead of €1,875 for 2024; €4,000 and €2,000 from 2025) and the married one-income band; with some income, a proportion based on your Irish share of the couple's income. Revenue expects proof of their income. See spouse living abroad.
- Emergency tax on your first payslips. New arrivals are taxed with no credits: 40% on everything from the first payslip if your employer doesn't have your PPSN, or from week 5 if they have it but the job isn't registered; it comes back once the job is registered, through payroll in the same year or on your return afterwards. See emergency tax.
- Parents in Morocco. Money you send home isn't deductible. The Dependent Relative Tax Credit, €305 a year for 2025 and 2026 (€245 for 2022 to 2024), applies to a widowed parent, or a relative who can't maintain themselves because of old age or infirmity, if you maintain them and their income is within the limit (€17,404 for 2024, €18,028 for 2025, €18,548 for 2026). The relative can live in Morocco; keep the transfer receipts. See the Dependent Relative Tax Credit.
Worked example: chef with a second job and a widowed mother in Fès
- Rachid, a hotel chef in Dublin, earned €30,000 plus €8,000 from a second job in 2024, paid €900 a month in rent and supports his widowed mother in Fès.
- Payroll took €5,450 in income tax; his correct bill is €2,585.60, so he's due €2,864.40.
- That's after the chef's flat rate expense, the Rent Tax Credit and the Dependent Relative Tax Credit.
Starting data (assumptions): Rachid was Irish resident and single for all of 2024. His main job paid €30,000 and carried his single credits (€1,875 personal and €1,875 employee) and the full €42,000 single standard rate band; his second job paid €8,000 and was taxed at 40% with no credits or band, because he never split them. He's a chef in a hotel kitchen (Hotel Industry flat rate expense €97) and paid €900 a month on an RTB-registered tenancy with an unrelated landlord. His mother is widowed, lives in Fès, has income below the €17,404 limit and he sends her money every month, with bank records. He claimed nothing during the year. USC and PRSI don't change in this example.
| Calculation | Amount | |
|---|---|---|
| Tax deducted through payroll, main job | €30,000 × 20% − (€1,875 + €1,875) | €2,250.00 |
| Tax deducted through payroll, second job | €8,000 × 40% | €3,200.00 |
| Total deducted | €2,250 + €3,200 | €5,450.00 |
| Taxable income after the flat rate expense | €38,000 − €97 | €37,903.00 |
| Tax at 20% (all within the €42,000 band) | €37,903 × 20% | €7,580.60 |
| Less personal and employee credits | €1,875 + €1,875 | −€3,750.00 |
| Less Rent Tax Credit | 20% × €10,800 = €2,160, capped at €1,000 | −€1,000.00 |
| Less Dependent Relative Tax Credit | 2024 rate | −€245.00 |
| Tax due | €7,580.60 − €3,750 − €1,000 − €245 | €2,585.60 |
| Refund | €5,450 − €2,585.60 | €2,864.40 |
The refund splits into €1,600 from the second job (€8,000 taxed at 40% instead of 20%), €19.40 from the flat rate expense (€97 × 20%), €1,000 of Rent Tax Credit and €245 for his mother. The second-job part would be zero if his total income were above the band, because 40% would then be the right rate. Splitting his credits and band between the two jobs in myAccount stops the overcharge for the current year; the past years come back only through a return for each one.
What Revenue actually asks for
- One Income Tax Return in myAccount for each year you claim, with your flat rate expense category, rent details and the dependent relative's details.
- For aggregation relief, add a declaration of your spouse's income; Moroccan income Ireland taxes goes on the same return, with the Moroccan tax as a credit.
- Refunds go to the bank account on your Revenue record.
- Sign in to myAccount with your PPSN and add your IBAN to your Revenue profile.
- Under PAYE Services, choose Review your tax for the previous 4 years and request a Statement of Liability for the year: with two jobs, this alone recalculates the 40% overcharge.
- Complete the Income Tax Return: add flat rate expenses (your hotel, bar, shop or hospital category), the Rent Tax Credit with the tenancy's RTB number where it has one and your landlord's details, and the Dependent Relative Tax Credit with your parent's details and income.
- For aggregation relief, record that you're married, state that you're electing for aggregation because your spouse isn't resident, and declare your spouse's income for the year: none, or the amount in euro. Keep your marriage certificate and evidence of their income ready.
- Declare Moroccan income that Ireland taxes (all of it if you're Irish-domiciled, what you brought in if you're not) and claim the credit for Moroccan tax on the same income, keeping the Moroccan receipt or withholding statement as proof.
- Repeat for each year from 2022 to 2025, and keep your records for six years.
If you'd rather not file four years yourself, our Tax Back service does it for you. No refund, no fee.
Where do you start?
If you were working in Ireland in 2022, start with 2022: it closes for good on 31 December 2026. If you had two jobs that year and your total pay was under the band, the Statement of Liability alone will show the second-job overcharge; everything else is added on the same return.
Related reading
- Tax on a second job in Ireland
- Spouse living abroad: the married tax credit
- Foreign rental income: a house back home and Irish tax
- The remittance basis for non-domiciled residents
- Leaving Ireland: split-year treatment and your refund
- Egyptian workers in Ireland: the treaty that taxes pensions where they're paid from
- Ireland's double tax treaties: the full country list
- Tax guides by nationality
Questions we get asked
Is there a double tax treaty between Ireland and Morocco?
Yes. It was signed on 22 June 2010 and has applied in Ireland since 1 January 2012. Revenue publishes no synthesised text with the OECD multilateral instrument for it, so it applies as signed.
Do I still pay tax in Morocco on my Irish salary?
Only if Morocco still treats you as resident (its first test is where your permanent home is) and the treaty's tie-breaker also comes down on Morocco's side, according to PwC's summary (reviewed April 2026); residents are taxed on worldwide income. In that case Ireland still taxes pay for work done here and Morocco must deduct the Irish tax from its own tax on it (Article 23(1)); if the tie-breaker makes you resident in Ireland, that pay is taxable only in Ireland (Article 15(1)). Ask a Moroccan adviser about your move year.
If I retire to Morocco, is my Irish pension taxed in Ireland?
An occupational pension, or a PRSA or annuity built up from your employment, is taxable only in Morocco under Article 18(1) once you're treaty-resident there, and Revenue can issue a PAYE Exclusion Order so it's paid without Irish tax. The State Pension does not: Article 18(4) keeps social security pensions taxable only in the country that pays them, so it stays within Irish tax. A public service pension (HSE, teachers, civil servants) stays taxable in Ireland unless you're also a Moroccan national.
I worked two jobs. Why was the second one taxed at 40%?
Because all your credits and standard rate band sat with the first job, so the second had none. If your total income for the year was inside the 20% band, the difference comes back when you request a Statement of Liability and file for that year. If it wasn't, the 40% was correct.
Will claiming a refund affect my visa or a citizenship application?
Tax and immigration are separate systems. Filing accurate returns and claiming the credits you're entitled to is ordinary tax compliance. For a specific immigration question, speak to an immigration solicitor.