Andorra and the Netherlands sign the Double Taxation Agreement

🕒 Reading time: 3 minutes

💡 Introduction

The Principality of Andorra and the Kingdom of the Netherlands have signed a Double Taxation Agreement (DTA) to eliminate double taxation, prevent tax evasion and avoidance, and strengthen economic relations between both countries.

The agreement entered into force on 31 December 2024, following the exchange of diplomatic notifications, and was officially published in the BOPA on 4 December 2024, confirming its enforceability in Andorra.

Given the economic importance of the Netherlands, this treaty is one of the most relevant in Andorra’s international tax network.

⚖️ Context and signature

The Agreement between the Principality of Andorra and the Kingdom of the Netherlands was signed in Marrakech on 12 October 2023, during the annual meetings of the IMF and World Bank.

The signatories were:

• César Marquina, Minister of Finance of the Government of Andorra.
• Marnix van Rij, Secretary of State for Taxation and Customs Policy of the Netherlands.

The Consell General ratified the treaty on 1 February 2024, published in the BOPA No. 26 on 28 February 2024.
After completion of domestic procedures, the treaty entered into force on 31 December 2024, as recorded in the edict published in BOPA No. 133 on 4 December 2024.

🧩 Key provisions of the DTA

Following the OECD Model Convention, the treaty governs both income and wealth taxes, ensuring transparency and cooperation.

Main provisions include:

• Tax residency: rules for determining where individuals and entities are taxable.
• Elimination of double taxation: credits or deductions for taxes paid in the other jurisdiction.
• Exchange of tax information: cooperation between tax administrations to prevent fraud and evasion.
• Anti-abuse clauses: safeguards to prevent treaty shopping or artificial arrangements.

It also covers taxation of dividends, interest, royalties, capital gains and pensions, providing legal certainty and fiscal predictability.

🕊️ Entry into force and application

According to Article 29 of the Agreement, the DTA entered into force on 31 December 2024, following the diplomatic exchange of notifications.

Its official publication in the BOPA on 4 December 2024 confirmed its domestic validity.

The DTA will apply for tax purposes:

• To withholding taxes on income paid or credited from 1 January 2025.
• To income and wealth taxes for fiscal years beginning on or after 1 January 2025.

🌍 Importance of the agreement

The treaty with the Netherlands is particularly significant due to the country’s role as a European financial hub and corporate headquarters for multinational groups.

Main benefits:

• For Andorra: strengthens its economic integration and international fiscal reputation.
• For the Netherlands: ensures legal certainty and predictability for investors.
• For businesses and investors: avoids double taxation and promotes cross-border capital flows.

This DTA reinforces Andorra’s commitment to OECD and BEPS standards, consolidating its position as a transparent and trusted jurisdiction.

🧭 Conclusion

The Double Taxation Agreement between Andorra and the Netherlands represents a landmark step in Andorra’s international tax strategy.
From 2025 onwards, it will provide greater fiscal clarity, stability and investor confidence in cross-border relations.

📚 Related articles

• Taxation in Andorra: structure, rates and real advantages — Comprehensive overview of the Andorran tax system.
• Tax residency in Andorra: requirements and benefits (2025) — Practical guide to determining effective tax residency.
• Double Taxation Treaties (DTTs) in Andorra (2025 update) — Updated overview of Andorra’s active bilateral agreements.

Last revision date: October 2025