DGI gains ground in the field of litigation
As tax audits become more precise, the face-to-face confrontation between tax authorities and taxpayers intensifies. In 2024, the number of claims lodged with the General Tax Directorate (DGI) rose by 14% to 90,030. At the same time, the DGI has speeded up processing: more than 82,000 cases were settled, 76% of them within a record 30 days. This increase illustrates the DGI’s shift towards litigation.
In the administrative phase, the DGI now intends to tightly control the progression of disputes. The management of claims is as much about guaranteeing taxpayers’ rights as it is about defusing disputes before they go to court. Each case is subject to an in-depth re-examination of the regularity of the disputed taxes and the accuracy of the tax bases.
The Business Tax (Tax Professionnelle) and the Income Tax alone account for 43% of disputes. While disputes relating to the Housing Tax and to the Communal Services Tax have fallen by 77%, appeals relating to the Income Tax and to the Business Tax have risen by 12% and 27% respectively.
Settlement of administrative disputes continued apace, with 82,464 cases settled. Of these, 78,632 cases were created and closed during the year, bringing their share to 95% of processed files (versus 89% in 2023). And 62,568 cases were settled within 30 days of filing, 7 points more than a year earlier.
The stock of claims stood at 12,617 files at the end of 2024 (+38%), driven mainly by business tax, corporate income tax and personal income tax, which accounted for 57%. These three categories show marked increases in stock: +49%, +42% and +43%.
At the same time, the tax authorities are not neglecting the upstream processing of avoidable disputes. The automatic tax relief without prior complaint made it possible to correct 1,331 cases, for an amount of 47.8 million dirhams, eliminating as many potential disputes.
Out-of-court settlements remain a strategic priority in the resolution of disputes. Tax appeals commissions play a key role in this pre-legal regulation. Local tax commissions reviewed 1,320 appeals (-15%), 88% of which related to income tax on property profits. The regional commissions dealt with 126 cases, the vast majority (95%) arising from tax audits. The National Tax Appeals Commission (CNRF) registered 487 appeals (-14%), 96% of which related to major audits. The pace of activity is clearly accelerating: 611 rulings issued (+20%), 93% of which concerned accounting audits.
Reinforced by the restructuring of the entities in charge of legal cases, the tax department’s policy aims to consolidate the administration’s positions upstream and to control the rise in appeals.
The legal front is not to be left out. The administrative courts recorded 1,251 appeals (+2%), for a sharp rise in the amount at stake: 1.63 billion dirhams, an increase of 41%. A total of 1,381 rulings were handed down, 879 of which were in favor of the administration, validating MAD 1.6 billion (USD 176 million) (76%) of the disputed amounts.
Khadija MASMOUDI
