Moroccan Rental Income in France or Canada: Are You Taxed Twice?
Two countries, two tax offices, one rent: a treaty decides who taxes it, and you declare on both sides.
It is the question that comes back every filing season: "I already pay tax on my rent in Morocco. Will France (or Canada) tax it a second time?" The short answer: no, not twice, but you must declare on both sides, and the mechanics differ depending on whether you live in France or in Canada. Two treaties signed half a century ago organise everything: the France-Morocco tax treaty, signed on 29 May 19701, and the Canada-Morocco tax treaty, signed on 22 December 19755. Here is what they actually say, and what that changes in your forms.
The shared rule: the country where the property sits taxes the rent
On income from immovable property, both treaties start from the same principle: rent is taxed where the property is located. A flat in Casablanca rented out all year is taxed first by the Moroccan tax authority, whether you live in Paris or Montreal. The French treaty is even more clear-cut than the usual model: such income "ne sont imposables que dans l'État où ces biens sont situés", taxable only in the state where the property is situated2. The Canadian treaty says this income "may be taxed in the Contracting State in which such property is situated", which leaves Canada the right to tax it too, provided it then eliminates the double charge6. That drafting nuance explains the whole difference between the two countries of residence.
On the Moroccan side, in both cases, your rents are declared and taxed in Morocco under Moroccan income-tax rules, with the Direction Générale des Impôts. Keep the proof: returns, assessments, payment receipts. They are what makes the rest work.
If you live in France: exempt, but counted for the "effective rate"
For a French tax resident, the treaty is unambiguous: France cannot tax your Moroccan rents. But it adds one sentence that changes everything: each state "conserve le droit de calculer l'impôt au taux correspondant à l'ensemble des revenus imposables", it keeps the right to set your tax rate by looking at your worldwide income3. That is the effective-rate mechanism (taux effectif): your Moroccan rents are never taxed in France, but they are counted when determining the rate applied to your French income.
One example to see the mechanism (illustrative numbers, not benchmarks): with a 40,000 EUR salary in France and the equivalent of 4,000 EUR of net Moroccan rents, France computes your tax rate as if you earned 44,000 EUR, then applies that rate to your 40,000 EUR of French income only. The Moroccan 4,000 EUR are not taxed in France, but they can push the rate applied to the rest upward. It is legal, it is in the treaty, and it is exactly why "taxed in Morocco" never means "nothing to declare in France".
In the forms, for 2025 income:
- Form 2047 (income received abroad) lists your Moroccan-source income.
- Exempt rental income goes straight into return 2042 C, line 4EA (régime réel) or 4EB (micro regime): the official 2047 notice says so expressly, exempt foreign rental income counted for the effective rate is declared on those lines, not in box 8TI, which is reserved for exempt income other than salaries, pensions and rental income4.
- And do not forget the accounts themselves: every Moroccan bank account is declared with form 3916, an obligation separate from the tax itself.
If you live in Canada: everything is declared, the credit removes the double charge
Canada follows another logic: a Canadian tax resident declares worldwide income, Moroccan rents included. The Canada Revenue Agency puts it plainly: taxpayers "must report their worldwide income from all sources, both inside and outside Canada"9. Your Moroccan rents therefore go into your Canadian return, on form T776 (Statement of Real Estate Rentals), lines 12599 and 126008.
Double taxation is then removed by a foreign tax credit: the treaty provides that Moroccan tax paid on that income "is fully deducted from the amount of any Canadian tax payable in respect of such profits, income or gains"7. In practice, you complete form T2209 (Federal Foreign Tax Credits) and carry the result to line 40500 of your return: for each country, the credit is the lesser of the foreign tax actually paid and the Canadian tax otherwise payable on that income8. One very concrete consequence: keep every proof of tax paid in Morocco, it is what your credit rests on. And if your Moroccan property cost more than 100,000 CAD, form T1135 joins the list.
France or Canada: the same rent, two mechanics
| France | Canada | |
| Who taxes the Moroccan rent | Morocco only | Morocco, then Canada with a credit |
| What your country of residence does | Exempts it, but counts it for the effective rate | Taxes worldwide income, then deducts Moroccan tax paid |
| Where it is declared | 2047, then 2042 C lines 4EA or 4EB | T776, then T2209 and line 40500 |
| The document never to lose | The breakdown of your net Moroccan income | The proof of tax paid in Morocco |
| The extra obligation | Form 3916 per account | T1135 above 100,000 CAD |
The three mistakes that cost real money
- Declaring nothing because "it is already taxed in Morocco". In France, the exemption does not remove the duty to declare (effective rate); in Canada, worldwide income is always declared. In both countries, the omission ends in penalties, not savings.
- Losing the Moroccan paperwork. In Canada, without proof of tax paid in Morocco there is no credit: the double charge becomes real. In France, without the breakdown of your Moroccan income, form 2047 becomes guesswork.
- Forgetting the account declarations. 3916 on the French side, T1135 on the Canadian side: reporting obligations separate from the tax, with their own penalties. They exist regardless of what Morocco does or does not exchange automatically.
Two tax offices, one clear picture
Rent in dirhams, tax in Morocco, a return in France or Canada: this is exactly the "life between two countries" Namup is built for. Your Moroccan property, its rents and what it really costs you fit in one picture, and your month in one calculation: income − commitments − savings = what you can spend, savings withheld at source, ranked like a bill. The rent arriving from Casablanca is not a vague bonus: it is a line of your wealth, visible, dated, with its obligations next to it.
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Frequently asked questions
I pay very little tax in Morocco on these rents. Do I still have to declare them in France?
Yes. The French exemption does not depend on how much you paid in Morocco: Moroccan rents are still declared (2047, then 4EA or 4EB on the 2042 C) and counted for the effective rate. Not declaring them is a reporting omission, even if the French tax on them is zero.
Does the effective rate really increase my French tax?
It can. Your Moroccan rents are never taxed in France, but they can push part of your French income into a higher bracket. The effect depends on your numbers: sometimes negligible, sometimes noticeable. It is the treaty's price for a clean exemption.
In Canada, what if the Moroccan tax is higher than the Canadian tax on that income?
The credit is capped: for each country, you deduct the lesser of the foreign tax paid and the Canadian tax otherwise payable on that income. If Morocco withheld more, the excess does not become a Canadian refund. Form T2209 runs that calculation line by line.
I am selling the property instead of renting it out: same logic?
The treaties also cover gains on sales, and Morocco taxes the sale of property located there first. But a sale opens a different project entirely, repatriating the proceeds: that is the subject of repatriating money from a property sale in Morocco.
- Convention between the Government of the French Republic and the Government of the Kingdom of Morocco for the elimination of double taxation, signed in Paris on 29 May 1970, in force since 1 December 1971, amended by the protocol signed in Rabat on 18 August 1989 (in force 1 December 1990). Official consolidated text, PDF, impots.gouv.fr, consulted July 2026. ↩
- France-Morocco convention of 1970, article 9: « Les revenus des biens immobiliers, y compris les bénéfices des exploitations agricoles et forestières, ne sont imposables que dans l'État où ces biens sont situés. » Article 4 defines immovable property to include rights covered by property-tax law and usufruct rights. ↩
- France-Morocco convention of 1970, article 25, paragraph 1: « Un État contractant ne peut pas comprendre dans les bases des impôts sur le revenu … les revenus qui sont exclusivement imposables dans l'autre État contractant …, mais chaque État conserve le droit de calculer l'impôt au taux correspondant à l'ensemble des revenus imposables d'après sa législation. » The paragraph-2 tax credit covers other categories (dividends, interest, royalties), not rental income. ↩
- Notice of form n° 2047 ("Revenus de source étrangère et revenus encaissés à l'étranger", 2025 income, n° 11226*28), section 8 "Revenus exonérés retenus pour le calcul du taux effectif": declare income « autres que les salaires, pensions et revenus fonciers … Reportez le total de ces revenus ligne 8TI de la déclaration n° 2042 C. Déclarez directement … vos revenus fonciers ligne 4EA (régime réel) ou 4EB (régime micro) sur la déclaration n° 2042 C sans les indiquer ci-dessous. » Form 2047, official PDF, impots.gouv.fr, consulted July 2026. ↩
- Convention between Canada and Morocco for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital, done at Ottawa on 22 December 1975, instruments of ratification exchanged and in force 9 November 1978 (Canada Treaty Series 1978 No. 11). Official text, canada.ca (Department of Finance), consulted July 2026. ↩
- Canada-Morocco convention of 1975, article VI "Income from Immovable Property", paragraphs 1 and 3: "Income from immovable property including income from agriculture or forestry may be taxed in the Contracting State in which such property is situated", including income "derived from the direct use, letting, or use in any other form of immovable property and … profits from the alienation of such property". ↩
- Canada-Morocco convention of 1975, article XXII, paragraph 1: subject to Canadian law on the deduction of tax paid abroad, "Moroccan tax payable under the tax laws of Morocco and in accordance with this Convention on profits, income or gains arising in Morocco is fully deducted from the amount of any Canadian tax payable in respect of such profits, income or gains." ↩
- Canada Revenue Agency, "Line 40500, Federal foreign tax credit" (2025 tax year): "Complete Form T2209, Federal Foreign Tax Credits, to calculate your federal foreign tax credit amount. In most cases, for each foreign country, you can claim whichever amount is less: The foreign income tax you actually paid; The tax otherwise payable in Canada on your net income from that country", carried to line 40500. Foreign rents are reported through form T776, lines 12599 (gross) and 12600 (net). canada.ca, CRA, consulted July 2026. ↩
- Canada Revenue Agency: taxpayers "must report their worldwide income from all sources, both inside and outside Canada". canada.ca, consulted July 2026. ↩