Andorra's double tax treaties: list, entry-into-force dates and what they change

What a treaty changes, and what it does not

A double tax treaty allocates the right to tax between two States (dividends, interest, royalties, salaries, capital gains, pensions), provides tie-breaker rules for residence and organises the elimination of double taxation. On its own it does not make income non-taxable, and it almost always contains clauses against abusive arrangements. For France, the 2013 Franco-Andorran treaty is detailed on the dedicated page: withholding tax on dividends capped at 5 %verified on 12/10/2026 for a company holding at least 10 %verified on 12/10/2026, 15 %verified on 12/10/2026 in other cases, interest at 5 %verified on 12/10/2026 and royalties at 5 %verified on 12/10/2026.

The table, with what we have been able to verify

This list is not exhaustive: we have not found an up-to-date official list from the Ministry of Finance, and several private sources give different totals. The dates marked "in force" come from the Consell General, from an official foreign register (Netherlands), from the British administration or from a specialist press publication relaying the government. Check the Butlletí Oficial before relying on a date.

Why the list matters for a company or a holding company

• Withholding taxes. An Andorran company receiving dividends, interest or royalties from a treaty country may benefit from reduced rates. See the exemption of shareholdings and the holding company guide.
• Condition for the Andorran exemption. The tax condition for the foreign subsidiary is deemed met for countries linked to Andorra by a treaty: the exemption at 5 %verified on 12/10/2026 of shareholding depends on it.
• Tax credit. Foreign tax paid in a country covered by a treaty is in principle deductible from Andorran tax within the limit provided by the treaty.
• Anti-abuse clauses. The benefits may be refused if the main purpose of a transaction is to obtain them, as in the treaty with France (articles 10 and 25).

For an individual

Treaties also settle the residence of a person who could be resident in two States. For a French person, the Franco-Andorran treaty provides a specific clause in article 25.1.d: see tax audits and residence. The treaties with Spain and Portugal are useful to Andorran residents who have income in those countries.

Key takeaway

A treaty never replaces the analysis of genuine residence and substance. It only sets who can tax what, once residence has been established.