Changes to the IRNR Regulation for seasonal workers: what has actually changed

Reading time: 5 minutes

🏁 Introduction

On 19 November 2025, a targeted amendment to the Regulation of the Non-Resident Income Tax (IRNR) was published in the BOPA. The change is highly specific and affects only the special regime for cross-border and seasonal workers, without modifying tax rates, taxable bases or general obligations.

If you want to understand how the IRNR works in Andorra, you can read The Non-Resident Income Tax (NRIT / IRNR) in Andorra.

This regime is particularly relevant because Andorran tax residents — who pay IRPF — enjoy exemptions and allowances that non-residents cannot access. The special regime allows certain workers to be taxed almost as if they were residents.

For more information on the IRPF/PIT, you can consult Personal income tax (IRPF or PIT) in Andorra

Until now, many workers, especially newcomers, were unaware of the regime or failed to exercise the option on time, losing significant tax advantages.

The 2025 reform aims to simplify, automate and prevent disadvantages caused by lack of information.

For a complete overview of Andorran taxation, you can read Taxation in Andorra: structure, rates and real advantages.

🎯 Key changes introduced

🔹 Automatic inclusion in the special regime

Cross-border and seasonal workers may now be automatically included when:

• the employer informs the Ministry of the worker’s intention
• within 10 days from the start of the contract

🔹 The employer may exercise the option on behalf of the worker

The option may be exercised either:

• by the worker, or
• by the employer appointed as tax representative through a written agreement

🔹 Removal of former Article 31.5

Article 31.5, which regulated telematic procedures now absorbed into the main system, is removed.

🔹 Clarification of the 10-day deadline

The 10-day requirement remains.

If exercised late but before year-end:

• the reduced withholding rate does not apply
• the regime can be applied through the final tax return

In summary

The reform introduces a simpler and more automatic system that prevents cross-border and seasonal workers from losing tax benefits due to administrative mistakes or lack of information.

The employer can exercise the option, procedures are unified, and Article 31.5 is eliminated. More workers will now be able to apply the special regime correctly and be taxed almost as residents.

If you would like us to review your situation or need personalised advice, you can request a meeting or complete the contact form.

Last revision: November 2025