Wealth structuring
Holding company in Andorra: dividends and capital gains exempt, provided you follow the rules.
A holding of 5 % for 12 months, a sufficiently taxed subsidiary, real substance: we check your case before you sign anything.
10 %
corporate income tax
5 %
minimum holding
12 months
of uninterrupted holding
3,000 €
minimum capital of an SL
Values checked against the official texts, October 2026.
9
jurisdictions compared with sourced figures
382
legal figures verified and dated
0
invented figures: everything is sourced
FR + AD
Andorran and French rules
Before setting up anything
The 5 pitfalls of a holding company in Andorra.
A holding company is a serious tool. It becomes dangerous when it is set up for the wrong reasons.
Pitfall no. 1
Believing it wipes out French tax.
A French tax resident remains taxable in France on the dividends they receive, and is exposed to the rules on entities under a preferential tax regime (articles 123 bis, 209 B and 238 A of the CGI). The holding company's country does not change personal tax.
Pitfall no. 2
Missing the holding period.
The exemption requires 12 months of uninterrupted holding before the dividend falls due, and at least 5 %. One day short, and ordinary-law tax applies.
Pitfall no. 3
Forgetting the investment authorisation.
For a non-resident shareholder, incorporation requires prior authorisation: decision within 2 months, and silence means refusal.
Pitfall no. 4
Running the holding company from France.
A company's residence is judged by its place of effective management. An Andorran holding company run from France may be taxed in France.
Pitfall no. 5
Neglecting the evidence file.
The burden of proving the exemption is on you. Without a register, dates and proof of the subsidiary's tax, the exemption may be refused even if the conditions were met.
Free simulator
Is your dividend exempt?
Percentage held, duration, subsidiary's country, ultimate shareholder: the three conditions are checked and the Andorran tax avoided is calculated.
Dividend received by the holding company
Exempt from corporate tax
Net kept by the holding company: €100,000
- Gross dividend
- €100,000
- Withholding tax (subsidiary's country)
- €0
- Andorran corporate income tax (10%)
- €0
- Tax avoided thanks to the exemption
- €10,000
- Holding percentage20% held for a minimum of 5%.
- Holding period18 months for a minimum of 12 months before the dividend due date.
- Tax borne by the subsidiaryCountry linked to Andorra by a treaty: condition deemed met.
When redistributed to an Andorran resident, the dividend of a resident entity subject to corporate income tax is exempt from IRPF (art. 5 j Llei 5/2014), subject to genuine residence.
The process
Six steps to a holding company that stands up to an audit.
- 1
Assessment of your situation
Current and intended tax residence, participations, subsidiaries, objective: we frame the project before incorporating.
- 2
Choice of structure
Holding company, SL alone or another country: we compare with figures, not slogans.
- 3
Investment authorisation
File prepared if a shareholder is not a resident, with the real timetable of the decision.
- 4
Incorporation
Articles, capital, notary, register, beneficial owners: with our partner professionals on site.
- 5
Substance and bank
Registered office, decisions, local accounting and compliance file for opening the account.
- 6
Evidence file
Share register, dates, proof of the subsidiary's tax: ready before the first distribution.
What you get
A structured opinion, as a firm would give.
A clear answer: holding company, SL or nothing, with the reasons.
Our commitment, in black and white
- Free assessment and first discussion, no obligation.
- You remain free to choose your professionals.
- No figure without a source and a date.
- We tell you if a holding company makes no sense for you.
This is probably not for you if…
- You stay in France and hope to escape tax there: the structure will not produce the expected effect.
- You want a company with no activity or real management: it is the greatest tax and banking risk.
- You are trying to conceal income: we do not work that way.
Included in your support
- Residence assessment : France, Andorra, or a move to prepare
- Choice of structure : holding company, SL alone or another country
- Exemption test : holding, duration, subsidiary's tax
- Authorisation file : if a shareholder is not a resident
- Substance and bank : registered office, decisions, compliance
- Evidence file : ready before the first distribution
- Client area and assistant : progress, documents, answers at any hour
Your objections
The questions every holding company owner asks.
Will an Andorran holding company save me tax?+
It exempts dividends and capital gains on participations from Andorran corporate income tax if the conditions are met. But personal tax depends on your residence: a French tax resident remains taxable in France. The difference at company level is in any case small compared with the French parent-subsidiary regime, which adds back only 5 % of dividends.
Do I need to be resident in Andorra?+
Not legally in order to hold the company, but a non-resident shareholder must obtain a foreign investment authorisation (decision within 2 months, silence means refusal), and the tax benefit presupposes genuine residence.
What are the conditions for the exemption?+
A holding of at least 5 %, without interruption for 12 months, in a subsidiary that bears at least 50 % of the general Andorran rate. The burden of proof is on you.
Is Andorra on the French blacklist?+
No, it does not appear on the list of non-cooperative States and territories in the order of 15 April 2026. Its rate may nevertheless bring it within the preferential tax regime, which exposes you to specific rules.
Would another jurisdiction be better?+
It depends on your residence, your subsidiaries and the substance you can provide. Our nine-country comparison gives dated, sourced figures, without an artificial ranking.
How much does it cost to work with you?+
The assessment and the first discussion are free and without obligation. Professionals' fees (lawyer, gestor, notary) are given to you in writing before any commitment, and you remain free to choose another professional.
Free assessment
Describe your situation. We will come back with a clear opinion.
- ✔ Free first discussion, no obligation
- ✔ A professional on site calls you back
- ✔ Your data is never resold
Prefer to talk right away? Our assistant answers at the bottom right, and you can book a slot.
Andorimo puts its visitors in touch with partner professionals based in Andorra, in whose business we hold a stake: see the transparency page on our remuneration. The figures are those of the current edition and show their verification date. No result is guaranteed: this page provides information and does not replace personalised legal or tax advice.
Our offices
Real offices in Andorra
Street-front windows, a welcome lounge and a team on site: book an appointment to meet us.
Edifici Sant Miquel, Carrer Callaueta, 14, AD500 Andorra la Vella, Andorre
Our team
- David F.Founder
- Sébastien PoliManager
Sophie ChiarraHead of customer relations