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Retiree in Andorra: proving your tax residence and avoiding the risks

The short answer

A retiree settling in Andorra must be an Andorran tax resident in fact: the treaty decides on the basis of the permanent home, then the centre of vital interests, then the habitual abode. Keep evidence, do not keep a main home in France and anticipate the Article 25 clause.

The treaty's tie-breaker criteria

Permanent home, then centre of vital interests, then habitual abode, then nationalityverified on 09/10/2026

In practice, a retiree who keeps their house, family and habits in France can be treated as a French resident, even with an Andorran residence permit.

Evidence to keep

  • Presence: records of days in Andorra, tickets, invoices, subscriptions. See the day counter.
  • Housing: lease or deed, utility bills, home insurance.
  • Social life and care: doctor, associations, bank, day-to-day life.
  • Ties with France: what you keep (home, accounts) must be explained.

The Article 25.1.d clause

France may tax French nationals resident in Andorra as if the convention did not exist; implementation is settled by mutual agreement between the competent authoritiesverified on 09/10/2026 Published analyses indicate that it has not been applied to date, but a legal risk remains: have it assessed by an adviser.

The test of the French criteria

French law treats you as having a tax domicile if any of the following criteria is met: home or main place of stay, main activity, centre of economic interests. Test your situation:

Test my tax domicile

The three retiree situations

SituationMain risk
Retiree genuinely settled, home and life in AndorraComplying with the presence calendar and the tax return
Retiree with residence in Andorra but house and family in FranceBeing judged a French resident under the home criterion
Retiree of French nationality settled in AndorraThe Article 25.1.d clause: France may tax as if the treaty did not exist

The four tie-breaker criteria

Permanent home, then centre of vital interests, then habitual abode, then nationalityverified on 09/10/2026 The Andorran residence permit is not enough: the administration looks at where the home is, where your economic ties are and where you actually stay.

Presence: two distinct thresholds

For Andorran residency as a passive retiree, the minimum presence is 90 daysverified on 12/10/2026 per calendar year. For Andorran IRPF, tax residence begins beyond 183 daysverified on 09/10/2026 of presence, or if the centre of interests is in Andorra. The two thresholds are not to be confused: see effective presence.

Good practices

  1. Keep a presence calendar with evidence every year.
  2. Have a real and lasting home in Andorra.
  3. Move your care, your bank, your social life.
  4. Declare your French-source income as French law requires.
  5. Do an annual review with an adviser who knows both countries.

Work out your own case

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Frequently asked questions

How many days must you spend in Andorra?

Andorran tax residence is defined by presence for more than half the year, but French law also looks at the home and economic interests.

Can I keep a home in France?

Yes, as a second home, provided your permanent home is genuinely in Andorra.

What happens in the event of an audit?

You must prove your residence: see the evidence to keep. An adviser can prepare the file before departure.

Going further

Official sources

This information is general and is not personalised legal, tax or financial advice. It is verified as of the date shown and may change.

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