“Alexis, I'm retiring to Marrakech. I've read everything and its opposite about the France–Morocco treaty. Does it protect my estate, yes or no?”

Morocco is home to 58,016 French nationals on the consular register as at 31 December 2025, up 3.82% year on year. It is the ninth-largest destination worldwide, and one of the oldest French communities outside Europe.

The Franco-Moroccan tax treaty of 29 May 1970 is often cited, rarely read. Yet the answer on inheritance is set out there in black and white, and it is more nuanced than what you hear on either side: the treaty contains no inheritance chapter, but it does contain one highly favourable specific provision, in Article 26 § 3.

At Balmont Conseil, we work on the text, not on what people say about it. It is the only way to know what you can rely on and what you cannot.

1. Why seek expert wealth management in Morocco?

Four issues arise for a French national living in Morocco.

  • The pension regime. Article 17 of the 1970 treaty allocates the taxation of pensions and life annuities to the State of the beneficiary's tax domicile, without distinguishing whether they are private or public. This is a notable feature compared with most French treaties.
  • The real scope of the treaty on inheritance. No dedicated chapter, but a precise exemption in Article 26 § 3. Knowing exactly what it covers avoids both unpleasant surprises and needless sacrifices.
  • The law applicable to your estate. Between French law, Moroccan law and the European regulation on international successions, the choice is not neutral — and it is made by will, during your lifetime.
  • Moroccan exchange controls. They strictly limit what a Moroccan resident may hold or fund abroad. This is a regulatory constraint, separate from tax, and it is checked locally.

2. The France ↔ Morocco framework in five verified points

Here is the applicable framework, checked against the text of the treaty itself and official sources as at 15 September 2026.

French nationals on the register58,016 as at 31 December 2025 (+3.82% year on year). Ninth-largest destination worldwide.
Income tax treatyYes — treaty of 29 May 1970 (Official Journal of 24 December 1971), amended by the protocol of 18 August 1989. Article 17 allocates the taxation of pensions and life annuities solely to the State of the beneficiary's domicile.
Estate tax treatyNo inheritance chapter, but one favourable specific provision: theArticle 26 § 3 states that “Moroccan securities forming part of the estate of a person of French nationality domiciled in Morocco are exempt in France from inheritance tax”.
Exit tax — deferral of paymentAutomatic deferral of payment. Morocco and France share both an exchange-of-information clause and a clause on assistance in recovering income tax.
CSG and CRDS on property income and capital gains17.2%. The CSG and CRDS exemption applies to members of a scheme in the European Economic Area, Switzerland or the United Kingdom. The France–Morocco social security agreement of 22 October 2007 does not extend it.
Sources: list of tax treaties concluded by France (BOI-ANNX-000306, updated 29 April 2026); exchange-of-information and recovery-assistance clauses (BOI-ANNX-000508, position at 8 October 2025); register of French nationals living outside France at 31 December 2025 (Ministry for Europe and Foreign Affairs); text of the treaty published by impots.gouv.fr; impots.gouv.fr for social charges on non-residents. Position as at 16 September 2026.

Article 26 § 3 is precise, and its precision is also its limit. In France, it exempts Moroccan securities forming part of the estate of a person of French nationality domiciled in Morocco. Three conditions, all of which must be met. Outside this scope — Moroccan property, for example — the treaty says nothing, and Article 750 ter of the French Tax Code applies in full.

Paragraph 3 of Article 750 ter therefore remains the point to watch. It makes taxable in France all assets received by an heir who has been domiciled in France for at least six of the last ten years. A riad owned in Marrakech and passed on to a child who stayed in France falls within the scope of French inheritance tax.

The Moroccan regime for foreign-source pensions and exchange controls do not appear in this table, and that is deliberate. We only show what we have verified in a primary source. These two points fall under Moroccan domestic law: they are handled with a professional authorised in Morocco, and we help you put the right questions to them.

3. Our services: 360° support for expatriates and investors

Three workstreams for a France–Morocco file.

Reading the treaty as applied to your assets

We go through your assets one by one and determine, for each, what the 1970 treaty provides — or does not provide. Moroccan securities fall under Article 26 § 3; Moroccan property does not; income follows Articles 9, 13, 14 and 17 according to its nature.

The result is a map of your exposure, item by item, with the reference of the applicable article. This is the document that then allows you to decide.

  • Asset-by-asset classification under the treaty text.
  • Exact scope of the exemption under Article 26 § 3.
  • Costing of Article 750 ter for the assets within its scope.

Choice of inheritance law and will drafting

For a French national habitually resident in Morocco, the law applicable to the estate is not self-evident. The European Succession Regulation allows you to choose the law of your nationality by will; failing that, other rules apply.

We work on this point with your notary, because it determines not only the tax but the very order of heirs and the reserved share. It is a decision to take during your lifetime, in a formal deed, not a question to leave open.

Pensions, French income and portability of savings wrappers

We check how your pensions are treated under Article 17 of the treaty and the formalities to complete with your pension funds. We monitor your French-source income: minimum rate for non-residents under Article 197 A of the French Tax Code, option for the average rate, IFI (real estate wealth tax).

On savings wrappers, we look at what to keep and what to switch, bearing in mind that a Luxembourg assurance-vie contract is not subject to the same portability constraints as a French-law contract. Compatibility with Moroccan exchange controls, for its part, is checked with a local professional.

4. Methodology: our way of working

We work in four stages, and at each stage you know where you stand.

  1. The initial review. We establish your actual situation: the make-up of your wealth, the project timeline, the situation of each member of the household, and the tax domicile of your heirs — because it is theirs that counts, not yours.
  2. The applicable framework. We set out, source by source and with its date, the framework that applies to you. What we do not know, we mark “to be confirmed” — never anything else.
  3. The choices. We present the options with figures and their respective consequences, and you decide. Wealth structuring comes after the decision, not before.
  4. Ongoing monitoring. An annual review, free of charge, to check that the framework has not moved — treaties are amended, incentive regimes are abolished, thresholds change.

5. What the firm offers you

What concretely sets our work apart.

  • Sources, not claims. Every item in your file carries its reference and its date. You can check. It is the only way to work on a subject where most of the information available online is out of date.
  • A single point of contact in France. We coordinate your local advisers; we do not replace them: the host country's domestic tax rules are handled with a qualified professional on the ground. Our role is to keep the whole picture consistent and to defend the French side of the file.
  • Fees that are easy to understand. Fees disclosed before any commitment: fixed-price reviews, tailor-made engagements at €500 incl. VAT per hour, insurers' commissions on contracts taken out. The annual review is free of charge.

Frequently asked questions: Morocco

Does the France–Morocco treaty cover inheritance?

Not in the sense of a full inheritance chapter, such as those France has with Germany or the United States. The treaty of 29 May 1970 governs income tax and registration duties, and contains a single inheritance provision, in Article 26 § 3.

This provision is real and useful: it exempts from French inheritance tax the Moroccan securities forming part of the estate of a French national domiciled in Morocco. It covers neither Moroccan property nor other categories of assets.

Will my house in Marrakech be taxed in France upon my death?

It may be. Article 26 § 3 of the treaty only covers securities; Moroccan property falls outside its scope.

Article 750 ter of the French Tax Code therefore applies. If an heir is domiciled in France on the date of transfer and has been for at least six of the previous ten years, France taxes all the assets they receive, including this property. That is the calculation we run in advance.

Will my retirement pensions be taxed in France or Morocco?

Article 17 of the 1970 treaty provides that pensions and life annuities are taxable only in the State where the beneficiary has their tax domicile, without distinguishing between private and public pensions.

This wording is more favourable than that of most French treaties, which generally reserve public pensions to the paying State. But your Moroccan tax domicile must still be established and documented, and the formalities completed with your pension funds.

Can I keep my French assurance-vie policy while living in Morocco?

The question has two sides, to be dealt with separately. The tax side falls under Moroccan law and must be checked with a professional authorised in Morocco. The regulatory side falls under the Office des changes, whose rules govern what a resident may hold or fund abroad.

We will not decide these two points for you: they require a written local position. What we do is tell you exactly what to ask, and adapt the structure of your assets to the answer obtained.

Is the exit tax a problem when moving to Morocco?

Less than elsewhere. Morocco is one of the States that have both required clauses with France — exchange of information and assistance in recovering income tax. The deferral of payment is therefore automatic, with no guarantee to provide.

Reporting obligations remain, as does the annual follow-up until the tax is discharged. We take care of them.


In summary

Morocco offers a partial treaty framework: favourable on pensions, favourable and precise on securities at death, silent on the rest. This is exactly the kind of situation where reading the text counts for more than the text's reputation.

The point to watch is Moroccan property passed on to heirs who stayed in France. It can be dealt with, but it must be dealt with in advance.

Firm's fees: €500 incl. VAT per hour. Annual follow-up is free of charge.

Let's review your situation

A thirty-minute conversation is enough to map what the treaty covers and what it leaves aside in your case. You can also start with a free contract X-ray.


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