New double taxation agreement with Andorra

By means of LN 118 of 2018, the Government has published a new double taxation agreement with The Principality of Andorra.Of particular interest is that Articles 10, 11 and 12 dealing with dividends, interest and royalties respectively give an exclusive right to tax to the State in which the recipient of the income is resident. Thus the country of source, i.e. the State in which the company paying the dividends is resident and the State where the interest and royalties arise will not have a right to tax the income. Double taxation relief is therefore provided for by having the source state exempting the income.