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Moving from Spain to Andorra can cut income tax from up to 47% to a maximum of 10%. But Spain treats a move to Andorra harshly: its exit tax (Article 95 bis) hits unrealised share gains above €4,000,000, or above €1,000,000 where you hold 25% or more of a company — and the payment deferral available for EU moves does not apply. Spain also audits Andorra relocations aggressively. This is a move that must be planned and documented before you go.
Spain’s top personal rate reaches around 47%, savings income is taxed up to 30%, and several regions levy a wealth tax and a “solidarity” tax on large fortunes. Andorra caps income at 10%, has no wealth tax, no inheritance tax and taxes most capital gains at 0%. For a Spanish business owner, investor or high-earning professional — and for creators, which is why so many have moved — the annual difference is very large.
If you have been Spanish tax resident for at least 10 of the last 15 years, Spain crystallises the unrealised gains on your shares when you emigrate, provided either:
The deemed gain is taxed at savings rates (currently up to about 30%). For a move to an EU/EEA country you can usually defer payment; Andorra is a third country and the deferral mechanism does not apply — the tax is payable, in principle immediately.
If you are on the Beckham Law (special impatriate regime), it simply ends when you leave Spain. There is no clawback of the benefit you already had, but you cannot carry it anywhere.
Because Andorra is a short drive from Barcelona and the tax gap is so wide, the Spanish tax authority (AEAT) looks closely at people who claim to have moved there. It will test:
High-profile creators who kept a Madrid flat, Spanish companies and Spanish partners while claiming Andorran residency are exactly the cases that end up reassessed and, sometimes, prosecuted. A real move — home, family, economic life in Andorra, minimal Spanish days — is the only version that holds.
Active residency through an Andorran company if you keep working; passive residency if you live off capital. The non-refundable €50,000 AFA payment applies, plus the day requirements (183 active, 90 passive). To defend the move you want to exceed the minimums comfortably in your first years.
Yes, under Article 95 bis, if your shareholdings exceed €4,000,000, or exceed €1,000,000 with a holding of 25% or more. Because Andorra is a third country, the payment deferral available for EU moves does not apply.
By testing your days in Spain (183 is the line), where your economic interests sit, and whether your spouse and minor children live in Spain. Weak facts lead to reassessment.
It ends on departure from Spain. There is no clawback, but the regime does not transfer.
The recurring saving is large for a high earner or business owner. Whether the one-off exit tax makes sense depends on the size and structure of your shareholdings — model it before you move.
Last reviewed: 3 September 2026. General information, not legal or tax advice. Spanish exit taxation and residence rules are complex and enforced; use a Spanish tax adviser and an Andorran adviser together before relocating. Speak to our team.
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