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France, Andorra May Reach Comprehensive DTA

By Ulrika Lomas,, Brussels

02 August 2012

A meeting between French President François Hollande, President of the Andorran parliament Vicenç Mateu Zamora and Head of the Andorran Government Antoni Marti at the Elysée Palace in Paris, discussed a new comprehensive DTA between France and Andorra.

In a speech, Hollande mentioned that many cross-border topics had been discussed during the summit, in particular with regard to tax matters.

“I know the work that is being done will lead to a Double Tax Convention (DTC)”, Hollande said, alluding to the introduction of elements of direct taxation in Andorra in 2012.

France's foreign policy towards Andorra with regard to a possible future comprehensive DTC has traditionally been to leave the door open for it, provided Andorra introduces some direct taxation on corporations and natural persons.

In 2011, Andorra introduced a unilateral withholding tax of 10% on Andorra-sourced income for non residents through the Taxation of Non-Residents Act in 2010. A corporate income tax of 5% has also been in place since January 2012 and is supposed to rise to 10% in 2013.

During his speech, Hollande said France and Andorra should improve their trade relations, and the cross-border road infrastructure. He also suggested that more investors should be encouraged to set up in Andorra, thereby signalling that France intends to channel inward foreign direct investments through Andorra.

Andorra still doesn't have any form of direct taxation for the capital income of resident high-net-worth Individuals, which might hamper the negotiations towards a comprehensive DTA.

TAGS: tax | investment | offshore confidentiality | double tax agreement (DTA) | banking | offshore | offshore banking | banking secrecy | withholding tax | France | Andorra

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