The Double Taxation Agreement between Andorra and France: a key step towards fiscal cooperation
The DTA between Andorra and France, in force since July 2015, prevents double taxation and strengthens fiscal cooperation and transparency between the two countries.
Elysium Consulting
Reading time: 10 minutes
The Double Taxation Agreement (DTA) between Andorra and France is one of the most significant tax treaties in Andorra’s international opening process.
Signed on 2 April 2013 and published in the BOPA No. 64 of 5 November 2014, this convention marked a historic milestone in bilateral relations, as it was the first tax treaty of its kind ever signed by Andorra with another State.
After a long ratification process in both countries, the Andorran Government announced on 15 June 2015 that the treaty would enter into force on 1 July of the same year, following official notification from France.
As the first Andorran DTA to enter into force, this agreement allows entrepreneurs and residents from both countries to avoid double taxation when operating or living across the border.
📜 Context and purpose of the DTA
The DTA between Andorra and France was signed in Paris by the Ministers Jordi Cinca (Andorra) and Pierre Moscovici (France), after several years of negotiation aimed at normalising fiscal relations between both countries.
Minister Cinca described the signing as “a guarantee for future agreements”, emphasising Andorra’s determination to align with OECD transparency standards and to leave the grey list.
The main objective of the DTA is to avoid the double taxation of the same income — both in Andorra and France — and to prevent tax fraud and evasion.
The agreement establishes credit and exemption methods, enhances administrative cooperation, and strengthens legal certainty for businesses, investors, and cross-border residents.
⚖️ Structure and content of the agreement
The DTA consists of 29 articles and an Additional Protocol, divided into six main chapters:
- Scope and definitions: defines who qualifies under the agreement and concepts such as “tax resident”, “permanent establishment”, or “source of income”.
- Taxation of income: determines which country has taxing rights over dividends, interest, royalties, salaries, pensions, and capital gains.
- Elimination of double taxation: sets out credit or exemption methods depending on the income type and residence.
- Special provisions: includes non-discrimination, the mutual agreement procedure, and exchange of information.
- Additional Protocol: introduces anti-abuse rules and provisions specific to real estate and holding companies.
The text follows the OECD Model Tax Convention, adapted to Andorra’s framework, and served as the reference point for subsequent agreements with Spain, Portugal, and Luxembourg.
➤ To learn more about how Andorra’s tax treaties are structured and which countries have active agreements, read Double Taxation Agreements (DTA) in Andorra
💬 Exchange of tax information
The DTA with France replaced the former Tax Information Exchange Agreement (TIEA) of 2009, establishing a regime of “foreseeably relevant” information exchange, in line with OECD standards and the BEPS Framework.
Since 1 July 2015, France and Andorra have been able to request and share tax information upon demand, strengthening cooperation in the fight against fraud and money laundering, and enhancing their reputation as transparent, cooperative jurisdictions.
This mechanism was crucial in aligning Andorra with international transparency practices and reinforcing its fiscal credibility within Europe.
🏦 Economic and fiscal impact
The entry into force of the DTA with France had an immediate impact on bilateral economic relations.
- Andorran companies operating in France obtained protection from double taxation and reduced withholding at source.
- Andorran tax residents earning French income gained the right to claim tax credits or exemptions according to the treaty.
- Tax administrations in both countries established a stable channel for cooperation, improving legal certainty and reducing residence conflicts.
This DTA paved the way for later agreements, such as the DTA with Spain (2015), and strengthened Andorra’s position as a transparent and reliable tax jurisdiction.
🧭 Key provisions
The most relevant provisions of the Andorra–France DTA include:
- Article 4 – Tax residence: defines residence in cases of dual domicile, prioritising the centre of vital interests.
- Article 7 – Business profits: allows taxation only in the country where a permanent establishment exists.
- Article 10 – Dividends: sets maximum withholding rates of 5% or 15%, depending on ownership. (In practice, dividends are taxed at a maximum of 12.8% at source.)
- Article 11 – Interest: limits withholding tax to 5%.
- Article 12 – Royalties: also sets a maximum rate of 5%.
- Article 25 – Exchange of information: establishes administrative cooperation between tax authorities with confidentiality guarantees.
- Article 26 – Anti-abuse clause: prevents misuse of the DTA to obtain unwarranted tax benefits.
➤ The full text can be consulted in the BOPA No. 64 of 5/11/2014 or in the official version published in the Journal Officiel de la République Française.
🌍 Strategic importance for Andorra
The DTA with France was not only the first international tax treaty signed by Andorra but also a key milestone in its integration into the European fiscal framework.
It helped normalise tax relations with France, Andorra’s main trading partner, and opened the door to new international alliances and the negotiation of the Association Agreement with the European Union.
➤ To better understand this process and its evolution, read Andorra and the European Union: an ongoing association process
Ultimately, the DTA with France ushered in a new era of international cooperation and remains a cornerstone of Andorra’s fiscal and foreign policy.
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📞 Would you like to know how the DTA with France applies to your situation?
At ELYSIUM, we help you apply international tax agreements correctly, avoid double taxation, and optimise your fiscal position with full legal certainty.
Contact us and we will analyse your personal or business situation.
Last review: November 2025
