Note: This Treaty may be impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). MLI impact on Tax Treaties is available with the Orbitax International Tax Research & Compliance Expert.
ARTICLE 22
Elimination of Double Taxation
(1) Subject to the provisions of the laws of Liechtenstein regarding the elimination of double taxation, which shall not affect the general principle hereof, double taxation shall be eliminated as follows:
- Where a resident of Liechtenstein derives income or owns capital which, in accordance with the provisions of this Convention, may be taxed in Andorra, Liechtenstein shall exempt such income or capital from tax, but may nevertheless, in calculating the amount of tax on the remaining income or capital of such resident, take into account the exempted income or capital.
(2) Subject to the provisions of the law of Andorra regarding the elimination of double taxation, which shall not affect the general principle hereof, double taxation shall be eliminated as follows:
- (a) Where a resident of Andorra derives income or owns capital which, in accordance with the provisions of this Convention, may be taxed in Liechtenstein, Andorra shall allow as a deduction from the tax on the income or capital of that resident an amount equal to the tax paid in Liechtenstein. Such deduction shall not, however, exceed that part of the Andorran tax, as computed before the deduction is given, which is attributable to such items of income derived from Liechtenstein.
- (b) Where a resident of Andorra derives income or owns capital which, in accordance with the provisions of this Convention, is exempt from tax in Andorra, Andorra may in order to calculate the amount of tax on the remaining income or capital of such resident, take into account the income or capital has been exempted.