Photo: Stephanie LeBlanc / Unsplash
Key Takeaways
- There is no double-taxation convention between Belgium and Andorra; Andorra has 22 in force and Belgium is not among them.
- The two countries share only an agreement to exchange tax information, in force since 13 January 2015.
- Belgian residence turns on domicile and the seat of your wealth, so deregistering at your commune is necessary but not enough.
- Belgium’s capital gains tax law of 6 April 2026 and the Cayman tax both need a Belgian adviser before you leave.
- Llei 2/2026 sets passive residency at €1,000,000, or €400,000 through the Housing Fund, plus a definitive €50,000 AFA payment.
There is no double-taxation convention between Belgium and Andorra. Andorra has conventions in force with 22 states and Belgium is not one of them; what the two countries share is an agreement to exchange tax information on request, in force since 13 January 2015. A Belgian moving to Andorra still gets the 10% ceiling on Andorran personal income tax (IRPF), but no treaty tie-breaker if Belgium goes on claiming them as resident, and no treaty limit on what Belgium can tax as they leave.
No treaty, one information agreement
Conventions with Romania and the United Kingdom entered into force in December 2025 and with Estonia in March 2026, bringing the total to 22. Belgium is still outside it. The Govern d’Andorra lists a Belgian text as initialled in 2023 and awaiting signature, but initialling has no legal effect and no convention has been published in the BOPA.
What does exist is the agreement on the exchange of information in tax matters, signed in Brussels on 23 October 2009 and in force since 13 January 2015. It lets Belgium ask Andorra about a named taxpayer. It does not decide which country may tax what.
| Mechanism | Under a double-taxation convention | Belgium and Andorra today |
|---|---|---|
| Tie-breaker if both countries claim you as resident | Yes: permanent home, centre of vital interests, habitual abode | None |
| Ceiling on Belgian withholding tax on income you leave behind | Yes | None: Belgian domestic rules apply |
| Mutual agreement procedure | Yes | None |
| Exchange of information | Yes | Yes: on request, and automatically for bank accounts |
Belgian residence does not end at the border
Under Article 2, §1, 1° of the Belgian Income Tax Code 1992, you are resident in Belgium if your domicile or the seat of your wealth is there, and registration in the National Register creates a presumption that it is. The first step is therefore formal: declare your departure at your commune, which issues the certificate of removal known as Model 8.
That step is necessary and it is not sufficient. The presumption can be rebutted, and without a treaty nothing settles a disagreement between the two countries. If your family, your main home or the management of your wealth stays in Belgium, Belgium can keep taxing you as a resident, whatever your Andorran permit says.
Two Belgian rules to settle before you leave
- The tax on capital gains on financial assets. Belgium taxes gains on financial assets under the law of 6 April 2026. It includes a charge when a holder moves abroad, and whether that charge can be deferred depends on the country you move to. Belgium has no convention with Andorra, so do not assume a deferral is available.
- The “Cayman tax”. Article 5/1 of the Income Tax Code, introduced by the Programme Law of 10 August 2015, looks through certain foreign companies and trusts and taxes their income in the hands of the Belgian-resident founder. If you hold investments through such a structure, decide what happens to it before the year you leave, not after.
The rates, thresholds and deferral conditions are deliberately absent. The official Belgian texts could not be consulted for this article, and a figure copied from a press summary is how somebody ends up with an assessment they did not plan for.
What Andorra asks of you
Llei 2/2026, del 22 de gener — the second Omnibus Law, published in the BOPA on 12 February 2026 — sets the current conditions for both routes.
| Requirement | Passive residency | Active residency |
|---|---|---|
| Investment in Andorran assets | €1,000,000, or €400,000 through the Housing Fund | An Andorran company you hold more than 34% of |
| If that investment is property | Unit value above €800,000 | Not applicable |
| Payment to the AFA | €50,000, definitive | €50,000, definitive |
| Each dependant | €12,000, definitive | Not applicable |
| Days in Andorra a year | 90 | 183 |
The €50,000 is no longer a deposit. It is returned only if the initial authorisation is refused.
What Andorra taxes once you are resident
Under Law 5/2014 on Personal Income Tax, the rate is 10% and the first €24,000 of income is exempt as the personal minimum. A Belgian business owner on active residency usually runs the work through the Andorran company, whose profit is taxed at 10% under Law 95/2010 on Corporate Income Tax. Belgian-source income you keep, such as Belgian rent, stays taxable in Belgium with no treaty ceiling.
How to sequence the move
- Take Belgian advice on the capital gains tax and on any structure you hold, before you sell, restructure or leave.
- Apply for the Andorran permit and, for active residency, set up the company.
- Declare your departure at your commune and keep the Model 8 certificate.
- Register with your Comú once the permit is granted.
- Request an Andorran tax residency certificate once you qualify. It is the document Belgium will ask for.
Frequently asked questions
Is there a double-taxation treaty between Belgium and Andorra?
No. Andorra has conventions in force with 22 states and Belgium is not among them. The two countries have only an agreement to exchange tax information, in force since 13 January 2015.
Does Belgium tax me when I leave for Andorra?
It can. The law of 6 April 2026 on capital gains on financial assets includes a charge on moving abroad, and the Cayman tax can reach structures you hold. Settle both with a Belgian adviser before you go.
Is deregistering at my commune enough to stop being resident in Belgium?
No. It removes the presumption that comes with registration, but Belgium still looks at where your domicile and the seat of your wealth are, and with no treaty there is no tie-breaker.
How much do I have to invest for Andorran passive residency?
Since Llei 2/2026, €1,000,000 in Andorran assets, or €400,000 through the Housing Fund, plus a definitive €50,000 payment to the AFA and €12,000 for each dependant.
Will Belgium find out about my Andorran bank account?
Yes. Andorra exchanges financial account information automatically with EU member states, Belgium included, under its agreement with the European Union.
Last reviewed: 2 October 2026. General information, not legal or tax advice. The Belgian rules here are described by instrument only; take the figures from a Belgian tax professional before you deregister. Speak to our team.
