1. Understand what the administration is contesting
A reassessment on real estate almost always turns on value. On the seller's side, the TPI (tax on real estate profits) hits the net gain — 20% of the profit, with a minimum contribution of 3% of the sale price; on the buyer's side, registration duties are based on the price. If the administration considers that the price expressed in the deed does not reflect the market value at the date of the sale, it notifies a revised value and recalculates the tax accordingly, with a 15% surcharge and late penalties.
Before contesting, identify precisely the ground of disagreement: sale value considered undervalued? original acquisition value contested (a frequent case with older properties)? For the mechanism of the audit and the signals that trigger it, see our article on the tax audit after a property sale.
2. The first notice — respond within 30 days
It all starts with the first reassessment notice, sent by the DGI (registered letter), reasoned and quantified. The taxpayer has 30 days from the date of notification to submit their written observations. This is the most important stage of the whole path: a solid file at this point can close the dispute, and it is what will serve as the base for all the following phases.
- Respect the 30-day deadline — this is imperative. Once it passes, the administration's position becomes almost final. Reply on time, even if your appraisal is not yet finalised, and complete the file afterwards.
- Attach the supporting documents — original acquisition deed, works invoices, expense receipts, bank traceability of the payment, and above all the market-value appraisal report.
- Ask for the administration's comparables — the revised value must be reasoned. You can ask to see the references used in order to contest their relevance.
3. The second notice
After your observations, the administration reviews the file and may maintain, revise or abandon its reassessment. If it persists, it sends a second notice that responds to your arguments and confirms (fully or partially) the position taken. The taxpayer keeps control: they can, again, put forward their observations and — above all — request that the dispute be referred to the tax appeal boards.
This is the moment to consolidate the value file: a complete and well-documented appraisal report at this stage avoids discovering, before the board, that the arguments rested on mere assertions.
4. The local tax appeal board
If the disagreement persists, the dispute is brought before the local tax appeal board (called, depending on the case, the departmental tax appeal board). It is an adversarial body: the taxpayer presents their defence memorandumand documents there, against the administration's position. The quality of the value documentation makes the difference — a dated, signed, methodologically explicit appraisal report carries weight in a way a verbal challenge does not.
For a detailed application case (contested older acquisition value, period comparables, structure of the memorandum), see our guide on defending against a tax reassessment on agricultural land.
5. The national tax appeal board, then the administrative court
If the decision of the local board does not end the dispute, the appeal continues before the national tax appeal board. And if the disagreement still persists after this stage, the taxpayer can refer the matter to the administrative court. At each tier, the value file is re-examined — hence the value of building it correctly from the first notice rather than improvising it as the instances go by.
- Written observations (30 days) → administration's response / second notice.
- Local (or departmental) tax appeal board → decision.
- National tax appeal board → decision.
- Administrative court → as a last resort, if the disagreement remains.
A useful clarification: the private real estate appraisal you produce documents the value and structures your argument, amicable as well as contentious, but it does not replace the expert the judge may appoint if deemed necessary. Before the boards and the court, your report is a piece of evidence to support your position with third parties — solid when it is rigorous, never a verdict.
6. The appraisal report — the centrepiece at every stage
Everything, from the first letter to the court, comes back to one question: what was the true market value of the property at the date of the sale? The market-value appraisal report, produced by a RICS-certified expert, is the tool that answers this question with method:
- Establish the value at the date that counts — that of the sale (retrospective value if the reassessment arrives years later): real condition of the property, wear, defects, works to be planned, rental situation.
- Contest the administration's comparables — demonstrate that they are not comparable (standing, floor, condition, legal situation) or too remote in time or space.
- Structure the defence memorandum — factual chronology, ordered documents, alternative calculation of the tax based on the defensible value, explicit request.
The cost of an appraisal — from 3,500 MAD excl. tax depending on the property — is out of all proportion with a reassessment suffered with no file, which quickly runs into tens of thousands of dirhams. Report compliant with RICS standards delivered within 5 to 8 days (48-72 h express), firm quote within 24 h. On the role of the notary and the value of an upstream appraisal, see our article on the notary and the appraisal before signing.
7. Anticipate rather than contest
The best appeal is the one you do not have to make. Two levers make it possible to lock in the value before the reassessment occurs:
- The request for a prior ruling from the DGI (article 234 quinquies of the CGI) — a ruling that, if followed, exempts you from audit. Deadlines, provisional payment, worked example: see our guide to the prior ruling on property capital gains.
- The appraisal before the sale — document the market value while the property is still accessible and the market observable. It is the documentary insurance that turns, when the day comes, a difficult challenge into a prepared defence.
For the detail of the rates, exemptions and the calculation mechanics, see our complete 2026 property taxation guide and the article on the TPI indexation coefficient.
8. FAQ
Do I have to pay the reassessed tax while I contest?
The challenge follows the adversarial procedure (observations, then tax appeal boards, then possibly the administrative court). The terms of collection and payment during this period fall under the texts in force: have your precise situation confirmed by your notary or a tax adviser, and never let the 30-day response deadline slip.
What if the 30-day deadline is too short to gather my appraisal?
Reply within the deadline with reasoned observations, announcing that an adversarial appraisal is to follow, and build the file without delay. The reflex to absolutely avoid: letting the 30 days pass without sending anything, because the administration's position then becomes almost final.
Is the private appraisal I produce binding on the administration or the court?
Not in the legal sense: the private appraisal is a piece of evidence that documents the value and supports your argument, amicable as well as contentious. It binds neither the administration nor the judge — who may, before the court, appoint their own expert. Its strength comes from its methodological rigour: a report compliant with RICS standards carries weight in the discussion.
How far can the appeal go?
Written observations after the first notice, second notice, local (or departmental) tax appeal board, national tax appeal board, and finally the administrative court as a last resort. At each stage, the value file is re-examined.
How much does an appraisal to defend my file cost?
From 3,500 MAD excl. tax depending on the type of property, its location and the complexity of the assignment, with a report compliant with RICS standards delivered within 5 to 8 days (48-72 h express). Firm quote within 24 h. An expense out of all proportion with a reassessment suffered for lack of a file.
Received a reassessment notice? The 30 days are already running.
RICS-certified experts — adversarial market-value appraisal and support for the defence memorandum, from the written observations to the administrative court. Reports compliant with RICS (Red Book) standards, within 5 to 8 days (48-72 h express), anywhere in Morocco.
Note: This article presents, for information purposes, the general path for contesting a reassessment on real estate (observations, tax appeal boards, administrative court). The deadlines, avenues of appeal and terms fall under the General Tax Code (CGI) and the texts in force — confirm your situation with a tax adviser or your notary. To document the market value of your property, see our real estate appraisal page or the real estate blog.