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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.


Taxes Covered

(1) This Convention shall apply to taxes on income and on capital imposed on behalf of a Contracting State or of its political subdivisions or local authorities, irrespective of the manner in which they are levied.

(2) There shall be regarded as taxes on income and on capital all taxes imposed on total income, on total capital, or on elements of income or of capital, including taxes on gains from the alienation of movable or immovable property, taxes on the total amounts of wages or salaries paid by enterprises, as well as taxes on capital appreciation.

(3) The existing taxes to which this Convention shall apply are in particular:

  • (a) in the case of the Principality of Liechtenstein:
    • (i) the personal income tax (Erwerbssteuer);
    • (ii) the corporate income tax (Ertragssteuer);
    • (iii) the real estate capital gains tax (Grundstücksgewinnsteuer);
    • (iv) the wealth tax (Vermögenssteuer); and
    • (v) the coupon tax (Couponsteuer);
  • (hereinafter referred to as "Liechtenstein tax");
  • (b) in the case of the Principality of Andorra:
    • (i) corporate income tax (impost sobre les societats);
    • (ii) personal income tax (impost sobre la renda de les persones físiques);
    • (iii) tax on income for fiscal non-residents (impost sobre la renda dels no residents fiscals); and
    • (iv) tax payable on the increase in value in immovable property transfers (impost sobre les plusvàlues en les transmissions patrimonials immobiliàries);
  • (hereinafter referred to as "the Andorran tax").

(4) This Convention shall apply also to any identical or substantially similar taxes that are imposed after the date of signature of this Convention in addition to, or in place of, the existing taxes, as well as any other taxes falling within paragraph 1 and 2 of this Article which a Contracting State may impose in the future. The competent authorities of the Contracting States shall notify each other of any significant changes that have been made in their taxation laws.