Part II of the MLI (Articles 3 to 5) introduces provisions to neutralise certain effects of hybrid arrangements on the basis of the recommendations made in the final reports of BEPS Action 2 and Action 6 published in October 2015. The provisions concern hybrid arrangements related to corporate transparency, non-resident companies and the elimination of double taxation. Not all of these provisions are minimum standards and, therefore, parties have the right to choose not to apply these provisions to their ESAs. 1. See EY Global Tax Alert, OECD publishes the Multilateral Instrument for the Implementation of Contract-Related BEPS Measures on Hybrid Devices, Contract Abuse, Status of Institutions and Dispute Settlement of 2 December 2016, for a more detailed analysis of BEPS measures related to MLI on hybrid design agreements, abuse of contracts, status of institutions and dispute resolution. The navigation area above allows you to access the texts of the corresponding agreements. The CNSS applies to wages paid by employers. Both the employer and the employee are subject to CNSS contributions on the employees` salary. The level of workers` contributions can be up to 6.74 per cent and 21.09 per cent for employers. Some contributions are capped, others are not.
CNSS contributions are deducted and paid monthly by the employer. Morocco has signed social security agreements with other countries/territories, mainly France, Belgium, the Netherlands, Spain, Sweden, Germany, Denmark, Tunisia, Canada and Portugal. There is no threshold/minimum number of working days in Morocco before the tax can be applied. However, the provisions of an international tax convention may provide for an exemption of wage income in Morocco, provided that the worker respects the threshold of the number of days he has spent outside Morocco during the period in question. DTAS aims to alleviate the double taxation of income received in one jurisdiction by a resident in another jurisdiction. The Singapore-Morocco DBA, in force since January 15, 2014, exempts from double taxation in the situation where income is taxable for both countries. Article 5 contains three options for parties to double taxation elimination methods. Option A provides that provisions of an LTT that would otherwise exempt from tax the income or capital of a resident of an enterprise established in a Contracting Country would not apply if the other Contracting Country applies the provisions of CTA to exempt such income or capital taxes or to limit the rate at which such income or capital may be taxed (conversion clause). Instead, a tax deduction with certain restrictions is allowed….