Becoming a tax resident in Andorra: conditions and proof

Conditions: who is a tax resident in Andorra?

The Andorran income tax law (Article 8) sets two alternative criteria. Meeting one of them is enough to be a tax resident:

• staying in Andorra for more than 183 days during the calendar year, including sporadic absences;
• having in Andorra the main core or base of your activities or economic interests, directly or indirectly.

The law adds a presumption: you are presumed to be an Andorran tax resident, unless proven otherwise, when your spouse, from whom you are not separated, and your minor children reside in Andorra. A tax resident is taxed on their worldwide income, with a deduction for tax paid abroad: see Andorran income tax (IRPF). Anyone who is not resident falls under non-resident income tax, on their Andorran income only; this is the case for cross-border workers who come in every day from France or Spain (see working in Andorra and living in France).

Becoming an Andorran tax resident: the steps

You do not apply for Andorran tax residency: it results from facts, assessed calendar year by calendar year. For a French national, the process in practice follows five steps, detailed in the guides of the Residency section and further down this page:

1. 1

   Choose your status and obtain the permit

   Employee, self-employed, international professional or passive resident: each status has its own conditions and minimum presence. The guidance test helps you choose; our guide explains how to obtain a residence permit.

2. 2

   Settle in for good

   Housing, registration on the census (padró) of your parish, affiliation to the CASS if you work: these formalities are also your first pieces of evidence.

3. 3

   Spend more than 183 days in Andorra, or establish the centre of your interests there

   The criterion is assessed over the calendar year: count your days of presence from the day you arrive.

4. 4

   No longer be domiciled in France

   None of the criteria of Article 4 B must still link you to France, unless the treaty designates you as a resident of Andorra: see the criteria of French tax domicile.

5. 5

   Declare your income in Andorra

   First income tax return from 1 April to 30 September of the following year; a tax residence certificate can then be requested from the Govern.

When do you remain domiciled in France for tax purposes?

French law has its own criteria, set by Article 4 B of the French General Tax Code. You remain domiciled in France for tax purposes if you meet just one of them:

Article 4 B of the CGI and administrative guidance (BOI-IR-CHAMP-10). A single criterion is enough.

Since 2020, the directors of companies whose registered office is in France and whose annual turnover exceeds €250 million have been considered, unless proven otherwise, to carry on their main activity in France. These domestic criteria do, however, give way to tax treaties, whose very role is to settle cases of dual residency: see our guide to the France⁠–⁠Andorra tax treaty.

Since 2025, treaty residence takes precedence (amended Article 4 B)

Since 16 February 2025, Article 4 B has said so expressly: meeting one of these three criteria no longer allows you to be considered domiciled in France for tax purposes if a tax treaty designates you as a resident of the other State. The subparagraph was added by Article 83 of the Finance Act for 2025 (Law No. 2025-127 of 14 February 2025).

For a French national living in Andorra who keeps a tie to France, everything therefore depends on the tie-breaker rules of the France⁠–⁠Andorra treaty, set out below: if they attribute your residence to Andorra, you can no longer be treated as domiciled in France, even if you still meet one of the criteria of Article 4 B. France keeps the right to tax the French-source income that the treaty allocates to it, and a mere Andorran residence permit still does not make you a resident of Andorra within the meaning of the treaty.

The treaty settles cases of dual residency

The same person can be resident in both countries under their respective laws. The 2013 France⁠–⁠Andorra tax treaty then settles the question, in two stages. First, it specifies who can be a resident of Andorra: a person who stays there for more than 183 days per calendar year, or who has the centre of their economic interests or their main professional activity there. The Protocol expressly excludes the mere holder of a residence permit:

Next, if dual residency persists, Article 4 applies successive criteria, in this order:

1. 1

   Permanent home

   You are a resident of the State in which you have a permanent home available to you.

2. 2

   Centre of vital interests

   If you have a permanent home in both States, the State with which your personal and economic relations are closer is chosen.

3. 3

   Habitual abode

   If this centre cannot be determined, or if you have no permanent home anywhere, the State where you habitually stay is chosen.

4. 4

   Nationality

   If you habitually stay in both States, or in neither, the State of which you are a national is chosen.

5. 5

   Agreement between the authorities

   As a last resort, the competent authorities of the two States decide by mutual agreement.

Passive or active residency: the permit is not enough

The right of residence and tax residency are two different things. Passive residency or the status of professional with international reach requires only 90 days of presence a year: enough to keep the permit, not to become a tax resident.

Four practical cases

Andorran residentSituation to be settledFrench resident

Proving your Andorran tax residency to the French tax authorities

In the event of a tax audit, it is the facts as a whole that count. Keep dated evidence:

• a count of your days of presence, calendar year by calendar year, with proof of travel;
• your lease or title deed in Andorra, and what happened to your former home in France;
• your registration on the census of your parish, which is also used as the basis for the foc i lloc;
• your affiliation to the CASS if you work, your contracts and the location of your clients;
• your children’s schooling and your spouse’s place of residence;
• the location of your accounts, your investments and the seat of your business;
• your income tax returns in Andorra and, to benefit from the treaty’s withholding caps on dividends, interest and royalties, an attestation of residence certified by the Andorran tax authority.

Formalities with the comú are presented in our guide to the seven parishes of Andorra. To keep track of your days of presence throughout the year:

Your days in Andorra

Count your days in Andorra over the year, against the 90-day and 183-day thresholds.

Open the counter

The tax residence certificate: useful, not sufficient

The tax residence certificate is requested from the Govern d’Andorra, with your NRT, the Andorran tax identification number. According to the official application form, it is either “standard” or issued under a double taxation treaty, it specifies the tax years covered, and an individual states on it the criterion for their residence (more than 183 days, or centre of their activities or economic interests), giving reasons in a signed statement.

Issued under the France⁠–⁠Andorra treaty, it certifies your residence for the purposes of applying the treaty; for the withholding tax caps provided for by the treaty, the treaty also provides for a residence attestation form certified by the Andorran tax authority. The CASS also asks for the certificate among the supporting documents for a French pension application submitted from Andorra. But it does not settle the question on its own on the French side: the French tax authorities assess the criteria of Article 4 B themselves, then those of the treaty. So keep the factual evidence listed above.

The year of arrival and the year of departure

The 183-day threshold is assessed per calendar year. Moving to Andorra during the year therefore does not always allow you to reach it in the first year: the criterion of the centre of activities or economic interests may then come into play, and the situation must be examined closely. On the French side, the year of departure is declared in two parts: income from 1 January to the date of departure as a resident, then French-source income as a non-resident. Everything is detailed in Leaving France for tax purposes.

Common misconceptions about tax residency