The Andorra Ministry of Finance has published the synthesized text of the tax treaties with Portugal, Spain, and the United Arab Emirates as impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). The synthesized texts were prepared on the basis of the reservations and notifications submitted to the Depositary by the respective countries. The authentic legal texts of the treaties and the MLI take precedence and remain the legal texts applicable.

The MLI applies for the 2015 Andorra-Portugal tax treaty:

• In Andorra:
  • with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2022; and
  • with respect to all other taxes, for taxes levied with respect to taxable periods beginning on or after 1 January 2023;
• In Portugal:
  • with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2022; and
  • with respect to all other taxes, for taxes levied with respect to taxable periods beginning on or after 1 July 2022.

The MLI applies for the 2015 Andorra-Spain tax treaty:

• In Andorra:
  • with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2023; and
  • with respect to all other taxes, for taxes levied with respect to taxable periods beginning on or after 1 January 2023;
• In Spain:
  • with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2023; and
  • with respect to all other taxes, for taxes levied with respect to taxable periods beginning on or after 1 January 2023.

Note, the synthesized text as published by Andorra includes that the MLI applies in Spain after Spain confirms the completion of its internal procedures for the entry into effect of the MLI. Spain confirmed this in respect of Andorra in June 2022, resulting in the above effective dates.

The MLI applies for the 2015 Andorra-UAE tax treaty:

• In Andorra:
  • with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2022; and
  • with respect to all other taxes, for taxes levied with respect to taxable periods beginning on or after 1 January 2023;
• In the UAE:
  • with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2022; and
  • with respect to all other taxes, for taxes levied with respect to taxable periods beginning on or after 1 July 2022.

Click the following link for the tax treaty page of the Ministry of Finance, which includes the MLI synthesized texts.