Andorra and Italy have no double-taxation convention. Andorra has conventions in force with 22 countries and Italy is not one of them, so an Italian moving to Andorra has no treaty tie-breaker if both countries claim the same residence, no treaty ceiling on Italian withholding tax, and no mutual agreement procedure to fall back on. The move still works — Andorra caps personal income tax (IRPF) at 10% — but it has to rest entirely on Italian domestic law and on the Andorran conditions that Llei 2/2026 made considerably more expensive from 13 February 2026.
Andorra has conventions in force with France, Spain, Portugal, Luxembourg, Liechtenstein, the United Arab Emirates, Malta, Cyprus, San Marino, Hungary, Croatia, the Czech Republic, Monaco, Iceland, the Netherlands, South Korea, Lithuania, Montenegro, Latvia, Romania, the United Kingdom and Estonia. Italy is absent from that list, and no Italy–Andorra convention has been signed.
Three consequences follow, and together they are why this is not the French move or the Dutch one:
Llei 2/2026, del 22 de gener — the second Omnibus Law — was published in the BOPA on 12 February 2026 and applies from the day after. It rewrote the numbers on 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 word that matters is definitive. Before Llei 2/2026 the €50,000 was a deposit you recovered when you left the country. It is now a final payment to the Andorran state, returned only if the initial immigration authorisation is refused. Applicants whose Andorran company pursues a recognised entrepreneurship, digital-economy or high-technology project can be exempted from it.
Passive residency suits someone living off capital. Alongside the investment, the Govern d’Andorra asks for 90 days a calendar year in the country, annual income above 300% of the Andorran minimum wage plus 100% of that figure for each dependant, proof of housing, and health, disability and old-age cover valid in Andorra.
Active residency suits someone who will carry on working: an Andorran company you hold more than 34% of and actually direct, 183 days a year, and the same definitive €50,000. For an Italian consultant or business owner, this is usually the cheaper of the two and the easier to evidence, because a real company in Andorra is itself proof that your economic life moved.
Two steps do the work, and both of them are Italian rather than Andorran.
Then the Andorran half of the evidence: registration with your Comú within a month of the permit being granted, an Andorran tax residency certificate once you qualify for one, and a life that visibly happens here. With no treaty to arbitrate, the documentation is the defence.
Every figure above is Andorran, and every one of them is taken from an official Andorran source — Llei 2/2026 as published in the BOPA, and the Govern d’Andorra procedure pages for residence without work. The Italian figures are deliberately absent. Italy’s residence rules, its treatment of citizens who move to low-tax states, and any charge on leaving are set in Rome, they have moved recently, and a rate copied from a relocation blog is exactly how somebody ends up with an assessment they did not expect. Take the Andorran half from this page and the Italian half from an Italian professional, before you deregister rather than after.
No. Andorra has conventions in force with 22 countries and Italy is not among them. There is no tie-breaker article for a residence dispute and no treaty ceiling on Italian withholding tax.
Since Llei 2/2026, €1,000,000 in qualifying Andorran assets, or €400,000 if the investment goes through the Housing Fund. If you use property, the unit has to be worth more than €800,000.
No. Llei 2/2026 turned it from a deposit into a definitive payment to the Andorran state, returned only if the initial immigration authorisation is refused. Passive applicants also pay €12,000 for each dependant.
90 days a calendar year on passive residency, and 183 days on active residency.
No. Deregistering and enrolling in AIRE is a formal step, not a conclusion. Italy tests residence on its own terms, and with no treaty tie-breaker to appeal to, the facts of the move have to be real and documented.
Last reviewed: 10 September 2026. General information, not legal or tax advice. This move needs an Italian tax professional and an Andorran one; neither half works alone. Speak to our team.