Ireland and Andorra have no double-taxation convention. Ireland is not on the Govern d’Andorra list of conventions, so an Irish person moving to Andorra has no treaty tie-breaker if both countries claim them as resident, and no treaty ceiling on Irish tax on income they leave behind. The move still works — Andorra caps personal income tax (IRPF) at 10% — but leaving Ireland is not the same as leaving Irish tax, because Irish ordinary residence outlasts your departure by several tax years.
Andorra publishes its conventions to avoid double taxation on the Govern d’Andorra tax pages. Ireland does not appear there. The convention Andorra signed with the United Kingdom of Great Britain and Northern Ireland covers Northern Ireland; it does not cover the Republic. What Ireland and Andorra do share is information: Andorra exchanges financial account data automatically with EU member states, Ireland included, under its agreement with the European Union.
| Mechanism | Under a double-taxation convention | Ireland and Andorra today |
|---|---|---|
| Tie-breaker if both countries claim you as resident | Yes: permanent home, centre of vital interests, habitual abode | None |
| Ceiling on Irish tax on income you leave behind | Yes | None: Irish domestic rules apply |
| Mutual agreement procedure | Yes | None |
| Automatic exchange of bank account data | Yes | Yes, through the EU–Andorra agreement |
Irish law separates two ideas that most countries merge. Residence, under section 819 of the Taxes Consolidation Act 1997, is a day count for each tax year. Ordinary residence, under section 820, is built up over several years of residence and is lost only after several consecutive years of non-residence.
The practical consequence is a tail. In your first tax years in Andorra you can be non-resident in Ireland and still ordinarily resident there, and during that period Ireland can continue to tax some of your income from outside Ireland. Income from work done wholly abroad is generally outside it; investment income may not be.
The thresholds, periods and rates behind these rules are deliberately absent. The official Irish 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.
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.
Under Law 5/2014 on Personal Income Tax, the first €24,000 of income is untaxed, the band to €40,000 is taxed at 5%, and income above that at 10%. An Irish consultant or 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. Irish-source income you keep, such as rent from an Irish property, stays within Irish tax with no treaty ceiling, and with no treaty there is no guarantee that Andorra will credit the Irish tax paid on it.
No. Ireland is not on Andorra’s list of conventions, and the UK convention covers Northern Ireland only. There is no tie-breaker for a residence dispute and no treaty ceiling on Irish tax on income you leave behind.
Ireland’s exit tax in section 627 applies to companies. For individuals the risk is section 29A: gains on significant shareholdings sold while abroad can be taxed if you return to Irish tax within a set period.
Not necessarily. Under section 820, ordinary residence continues for several tax years after you leave, and during that time Ireland can still tax some of your income from outside Ireland.
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.
Yes. Andorra exchanges financial account information automatically with EU member states, Ireland included, under its agreement with the European Union.
Last reviewed: 5 October 2026. General information, not legal or tax advice. The Irish rules here are described by instrument only; take the figures from an Irish tax professional before you leave. Speak to our team.