Dividends from an Andorran company for a French resident
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The short answer
The taxation of dividends depends on the shareholder's tax residence. A shareholder who remains tax-domiciled in France remains in principle taxable in France on these dividends; a shareholder who is genuinely resident in Andorra falls under the Andorran regime, subject to anti-abuse rules.
Two separate questions
- Where is the shareholder tax-domiciled? This is the central question. See leaving France for tax purposes.
- Where is the company actually managed? An Andorran company managed from France may be treated as established in France.
Typical cases
| Situation | Likely taxation (to be validated) |
|---|---|
| Shareholder genuinely resident in Andorra, company with substance | Andorran regime (IRPF on capital income, company tax) |
| Shareholder domiciled in France, Andorran company | Taxation in France, with possible anti-abuse rules |
| Shareholder "in between" | Potential dispute |
Going further
See corporate income tax (rate: 10 %verified on 09/10/2026) and IRPF.
What Andorran law allows a company to distribute
A company may distribute dividends only out of the positive result for the year or freely available reserves, after allocation to the legal or statutory reserves, and provided that its equity does not fall below its share capital. The decision is taken by the meeting that approves the accounts.
Andorran taxation depending on the shareholder
| Shareholder | Andorran treatment of the dividend |
|---|---|
| Andorran resident | Exempt from IRPF if it comes from a resident entity subject to corporate income tax (art. 5 j Llei 5/2014) |
| Non-resident | Capital income of Andorran source exempt from IRNR (art. 15 Llei 94/2010); taxation according to the country of residence |
| Shareholder holding company | Exemption from corporate income tax if the holding conditions are met: see participation exemption |
And if the shareholder is French?
A French tax resident remains taxable in France on the dividend, whatever the country of the company. The France–Andorra treaty caps the withholding tax of the source country at 5 %verified on 12/10/2026 for a company holding at least 10 %verified on 12/10/2026 of the capital, and 15 %verified on 12/10/2026 in other cases, subject to its anti-abuse clauses. See holding companies and the French tax authorities.
Distribute or leave it in the company?
Keeping profits in the company avoids immediate personal taxation, but settles nothing if the shareholder remains a French tax resident: the rules on foreign structures under a privileged regime may then tax the shareholder even without a distribution. The choice depends on the shareholder's real residence, plans for reinvestment and the intended exit.
Work out your own case
Free simulators, built on the official values of this page.
- Andorra IRPF simulator (employment, rental and savings income)Estimate your income tax with the tax-free minimum, the bonus relief and family allowances.Open
- Andorran holding simulator: exemption of dividends from shareholdingsDoes your dividend meet the exemption conditions? Tax avoided and net amount kept.Open
- Cost of an employee and corporate tax in Andorra: calculatorEmployer contributions, net pay before tax and a company's corporate tax.Open
Frequently asked questions
I am resident in Andorra and my company is Andorran: are the dividends taxed in France?
If you are no longer tax-domiciled in France, they are in principle not taxed as income of a French resident. But France may challenge the reality of your departure or of the company.
What anti-abuse rules may apply?
French law provides mechanisms targeting foreign companies under a privileged tax regime controlled by French residents, and abuse of law. Their application depends on the facts.
Can the company keep its profits without distributing them?
Yes, but undistributed profits do not settle the question of the shareholder's taxation, particularly if he or she remains domiciled in France.
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.