France–Andorra tax treaty: what it really provides
- Updated on
- La rédaction
The short answer
Tax relations between France and Andorra are governed by bilateral agreements, notably on exchange of information and avoidance of double taxation. Their practical effect depends on your tax residence and the nature of your income.
Two separate subjects
- Exchange of information: the tax authorities pass on financial information about taxpayers to each other.
- Allocation of the right to tax: if you may be considered resident by both States, tie-breaker rules apply.
What this changes for you
- Your Andorran accounts and income are not "invisible" to France.
- An Andorran residence without substance cannot be relied on against France.
- A genuine and documented residence makes your defence simpler in the event of an audit.
Going further
See the French criteria and IRPF.
The articles to know
The treaty has been Signed in Paris on 2 April 2013, entered into force on 1 July 2015 (decree of 17 July 2015)verified on 09/10/2026. Its most useful articles for a person or company linked to both countries:
| Article | Subject | What it says |
|---|---|---|
| 4 | Residence | Tie-breaker for a person resident in both States: Permanent home, then centre of vital interests, then habitual abode, then nationalityverified on 09/10/2026. For a company, the place of effective management |
| 10 | Dividends | Withholding 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 otherwise |
| 11 and 12 | Interest and royalties | Withholding capped at 5 %verified on 12/10/2026 for interest and 5 %verified on 12/10/2026 for royalties |
| 13 | Capital gains | Real estate: taxable where it is located. Substantial shareholdings (at least 25 %verified on 12/10/2026 of profits): in the State of the company. Other assets: State of residence of the seller |
| 14 | Salaries | Taxable in the State of residence, unless the employment is exercised in the other State: they are then taxable in that other Stateverified on 09/10/2026 Short-stay exception of 183 daysverified on 09/10/2026 under three conditions |
| 15 | Directors' fees | Taxable in the State of the company |
| 17 and 18 | Pensions | Private: Taxable only in the State of residence of the beneficiary, subject to Article 25 (portion exempt or not taxable in that State)verified on 09/10/2026 Public: Taxable only in the State that pays them, unless the beneficiary resides in the other State and is a national of that State without being a national of the paying Stateverified on 09/10/2026 |
| 19 | Students | Sums received for maintenance, studies or training: not taxable in the host State if they come from abroadverified on 09/10/2026 |
| 21 | Double taxation | Income taxable in Andorra is taken into account for French tax, with a tax credit equal to the corresponding French tax if the resident of France is subject to Andorran tax on that incomeverified on 09/10/2026 |
| 24 | Exchange of information | The agreement of 22 September 2009 remains applicable |
| 25 | Miscellaneous | Anti-abuse 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 |
The short-stay exception in detail
For an employee resident in one State who works in the other, article 14.2 requires three cumulative conditions: a stay in the other State not exceeding 183 daysverified on 09/10/2026 over twelve months, remuneration paid by an employer who is not resident in the State of activity, and a cost not borne by a permanent establishment of the employer in that State.
The clause that concerns French nationals
Article 25.1.d allows France to tax individuals of French nationality who are resident in Andorra as if the treaty did not exist. This clause provides that, where French legislation permits its application, the competent authorities settle its implementation by mutual agreement. It explains why a French person settling in Andorra must examine their situation precisely and not assume that the treaty protects them in every case.
The anti-abuse clauses
Article 25 denies the benefits of the treaty where one of the principal purposes of a transaction is to obtain them, and may deny them on an item of income where the recipient is not the beneficial owner and thereby reduces the tax burden. Article 10 contains its own clause on dividends. See holding company and the French tax authorities.
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
- Leaving France for Andorra: are you still a French tax resident?The three criteria for French tax residence, in a few questions.Open
- Quiz: which residency status in Andorra?A few questions, a clear lead towards the right status.Open
Frequently asked questions
Does the treaty eliminate double taxation?
It provides rules for allocating the right to tax between the two States when a person potentially falls under both. The precise arrangements depend on the text in force and the nature of the income.
Are my Andorran accounts known to the French tax authorities?
Andorra takes part in automatic exchange of financial information mechanisms. You should assume that the accounts are known and declare accordingly.
What is the rule if I am resident in both countries?
Treaties generally provide tie-breaker criteria (permanent home, centre of vital interests…). The exact text must be consulted.
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.