1887

Andorre

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This report analyses the implementation of the AEOI Standard in Andorra with respect to the requirements of the AEOI Terms of Reference. It assesses both the legal frameworks put in place to implement the AEOI Standard and the effectiveness of the implementation of the AEOI Standard in practice.

Andorra can legally issue the following five types of rulings within the scope of the transparency framework: (i) preferential regimes; 1) Holding company regime and 2) Special regime for exploitation of certain intangibles. (ii) cross-border unilateral APAs and any other cross-border unilateral tax rulings (such as an advance tax ruling) covering transfer pricing or the application of transfer pricing principles; (iii) rulings providing for unilateral downward adjustments; (iv) permanent establishment rulings; and (v) related party conduit rulings.

Andorra can legally issue the following five types of rulings within the scope of the transparency framework: (i) preferential regimes; 1) Holding company regime and 2) Special regime for exploitation of certain intangibles. (ii) cross-border unilateral APAs and any other cross-border unilateral tax rulings (such as an advance tax ruling) covering transfer pricing or the application of transfer pricing principles; (iii) rulings providing for unilateral downward adjustments; (iv) permanent establishment rulings; and (v) related party conduit rulings.

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