Common use of Morocco Clause in Contracts

Morocco. 1. Does an APA procedure exist in your jurisdiction? If so, are the APAs which can be concluded on a unilateral, bilateral or multilateral basis? What is the legal force of an APA? 2. What are the main steps of the procedure? What is the average time required to negotiate and conclude an APA? 3. Is it possible to first contact the tax authorities on an anonymous basis? 4. What documents must be produced by the company upon the official filing of the APA request? 5. Are the documents produced to the tax authorities kept confidential? What is the situation with regard to other authorities and third parties? Are the tax authorities which are responsible for auditing companies informed regarding APA requests and the conclusion of APAs? 6. Can the tax authorities widen the scope of the request filed by the taxpayer? 7. What is the first financial year which can be covered by an APA? What is the term of validity of an APA? Can an APA be adopted with retroactive effect? 8. What obligations are incumbent on a company which has obtained an APA? 9. Is it possible to renew an APA? If so, what are the conditions relating to such renewal? 10. Is the filing of an APA request subject to a fee? 11. What department is in charge of APAs? What are its contact details? 12. Do the tax authorities publish reports on their APA programme? Do the tax authorities encourage APAs? ▇▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇▇▇▇▇▇▇▇ ▇▇ ▇▇▇▇▇ Netherlands Advanced Pricing Agreements (“APA”) 1. Does an APA procedure exist in your jurisdiction? If so, are the APAs which can be concluded on a unilateral, bilateral or multilateral basis? What is the legal force of an APA? 2. What are the main steps of the procedure? What is the average time required to negotiate and conclude an APA? 3. Is it possible to first contact the tax authorities on an anonymous basis? 4. What documents must be produced by the company upon the official filing of the APA request? 5. Are the documents produced to the tax authorities kept confidential? What is the situation with regard to other authorities and third parties? Are the tax authorities which are responsible for auditing companies informed regarding APA requests and the conclusion of APAs? 6. Can the tax authorities widen the scope of the request filed by the taxpayer? 7. What is the first financial year which can be covered by an APA? What is the term of validity of an APA? Can an APA be adopted with retroactive effect? 8. What obligations are incumbent on a company which has obtained an APA? 9. Is it possible to renew an APA? If so, what are the conditions relating to such renewal? 10. Is the filing of an APA request subject to a fee? 11. What department is in charge of APAs? What are its contact details? 12. Do the tax authorities publish reports on their APA programme? Do the tax authorities encourage APAs?

Morocco. 1. Does an APA procedure exist in your jurisdiction? If so, are the APAs which can be concluded on a unilateral, bilateral or multilateral basis? What is the legal force of an APA? 2. What are the main steps of the procedure? What is the average time required to negotiate and conclude an APA? 3. Is it possible to first contact the tax authorities on an anonymous basis?? Yes. In practice, the authorities may be contacted on an anonymous basis, which may then be completed by providing personal information and supporting documents. The authorities may issue written replies or carry out specific cases studies, which create the authorities’ doctrine that can be compared to replies to taxpayers outside of the scope of any specific proceedings. 4. What documents must be produced by the company upon the official filing of the APA request? 5. Are the documents produced to the tax authorities kept confidential? What is the situation with regard to other authorities and third parties? Are the tax authorities which are responsible for auditing companies informed regarding APA requests and the conclusion of APAs? 6. Can the tax authorities widen the scope of the request filed by the taxpayer? 7. What is the first financial year which can be covered by an APA? What is the term of validity of an APA? Can an APA be adopted with retroactive effect? 8. What obligations are incumbent on a company which has obtained an APA? 9. Is it possible to renew an APA? If so, what are the conditions relating to such renewal? 10. Is the filing of an APA request subject to a fee? 11. What department is in charge of APAs? What are its contact details? 12. Do the tax authorities publish reports on their APA programme? Do the tax authorities encourage APAs? ▇▇▇▇▇▇▇▇ ▇▇▇▇▇ ▇▇▇▇▇▇▇▇ ▇▇ ▇▇▇▇▇ Netherlands Advanced Pricing Agreements (“APA”) 1. Does an APA procedure exist in your jurisdiction? If so, are the APAs which can be concluded on a unilateral, bilateral or multilateral basis? What is the legal force of an APA? 2. What are the main steps of the procedure? What is the average time required to negotiate and conclude an APA? 3. Is it possible to first contact the tax authorities on an anonymous basis? 4. What documents must be produced by the company upon the official filing of the APA request? 5. Are the documents produced to the tax authorities kept confidential? What is the situation with regard to other authorities and third parties? Are the tax authorities which are responsible for auditing companies informed regarding APA requests and the conclusion of APAs? 6. Can the tax authorities widen the scope of the request filed by the taxpayer? 7. What is the first financial year which can be covered by an APA? What is the term of validity of an APA? Can an APA be adopted with retroactive effect? 8. What obligations are incumbent on a company which has obtained an APA? 9. Is it possible to renew an APA? If so, what are the conditions relating to such renewal? 10. Is the filing of an APA request subject to a fee? 11. What department is in charge of APAs? What are its contact details? 12. Do the tax authorities publish reports on their APA programme? Do the tax authorities encourage APAs?