Editorial proof done by SK. Punctuation and spelling fixed.

Andorra-France Income Tax Treaty Available

Tax Analysts has prepared an English translation of the Andorra-France income tax treaty signed April 2, 2013, in Paris. The treaty entered into force July 1, 2015, and applies from January 1, 2016. It stipulates that dividends are taxable at a rate not to exceed 5 percent if the beneficial owner is a company (other than a partnership) that directly holds at least 10 percent of the capital of the payer company. A 15 percent rate applies in other cases. Interest is subject to a 5 percent withholding rate. Exemptions apply if the interest is paid on the credit sale of industrial, commercial, or scientific equipment; on the credit sale of goods or merchandise; or on the provision of services by one enterprise to another enterprise. An exemption also applies to interest paid by a financial institution of one contracting state to a financial institution of the other state. Royalties are taxable at a top rate of 5 percent. However, an exemption applies to royalties paid as a consideration for the use of, or the right to use, a copyright (excluding royalties relating to computer software, cinematographic films, and other means of image or sound reproduction). Both countries generally use the credit method to eliminate double taxation.

<a href="/lr/resolve/source-document/1x2x7" title="Source document">Catalan text</a>; <a href="/lr/resolve/source-document/1x1p2" title="Source document">French text</a>.

Tax Analysts has prepared an English translation of the Andorra-France income tax treaty signed April 2, 2013, in Paris.

Tax Analysts has prepared an English translation of the Andorra-France income tax treaty signed April 2, 2013, in Paris. The treaty entered into force July 1, 2015, and applies from January 1, 2016. It stipulates that dividends are taxable at a rate not to exceed 5 percent if the beneficial owner is a company (other than a partnership) that directly holds at least 10 percent of the capital of the payer company. A 15 percent rate applies in other cases. Interest is subject to a 5 percent withholding rate. Exemptions apply if the interest is paid on the credit sale of industrial, commercial, or scientific equipment; on the credit sale of goods or merchandise; or on the provision of services by one enterprise to another enterprise. An exemption also applies to interest paid by a financial institution of one contracting state to a financial institution of the other state. Royalties are taxable at a top rate of 5 percent. However, an exemption applies to royalties paid as a consideration for the use of, or the right to use, a copyright (excluding royalties relating to computer software, cinematographic films, and other means of image or sound reproduction). Both countries generally use the credit method to eliminate double taxation.

<table> <tbody> <tr> <td> Rate Type </td> <td> Base Country </td> <td> Applies To </td> <td> Rate </td> <td> Footnote1 </td> <td> Footnote2 </td> <td> Footnote3 </td> <td> Footnote4 </td> </tr> <tr> <td> Dividends </td> <td> Andorra </td> <td> France </td> <td> 5/15 </td> <td> The 5 percent rate applies if the beneficial owner is a company (other than a partnership) that directly holds at least 10 percent of the capital of the payer company; in other cases, the 15 percent rate applies. Dividends are taxable at the domestic rate of the state in which they arise if they are paid out of income or gains derived from immovable property by an investment vehicle that distributes most of the income annually and whose income or gains from the immovable property are tax-exempt, where the beneficial owner holds 10 percent of the capital of the vehicle paying the dividends. </td> <td> </td> <td> </td> <td> </td> </tr> <tr> <td> Interest </td> <td> Andorra </td> <td> France </td> <td> 0/5 </td> <td> The zero percent rate applies to interest paid: on the credit sale of industrial, commercial, or scientific equipment; on the credit sale of goods or the provision of services by one enterprise to another enterprise; or by a financial institution of one contracting state to a financial institution of the other contracting state. The 5 percent rate applies in other cases. </td> <td> </td> <td> </td> <td> </td> </tr> <tr> <td> Royalties </td> <td> Andorra </td> <td> France </td> <td> 0/5 </td> <td> The zero percent rate applies to royalties paid for the use of, or the right to use, a copyright (excluding royalties for computer software, cinematographic film, or other sound or image recordings). The 5 percent rate applies in other cases. </td> <td> </td> <td> </td> <td> </td> </tr> <tr> <td> Dividends </td> <td> France </td> <td> Andorra </td> <td> 5/15 </td> <td> The 5 percent rate applies if the beneficial owner is a company (other than a partnership) that directly holds at least 10 percent of the capital of the payer company; in other cases, the 15 percent rate applies. Dividends are taxable at the domestic rate of the state in which they arise if they are paid out of income or gains derived from immovable property by an investment vehicle that distributes most of the income annually and whose income or gains from the immovable property are tax-exempt, where the beneficial owner holds 10 percent of the capital of the vehicle paying the dividends. </td> <td> </td> <td> </td> <td> </td> </tr> <tr> <td> Interest </td> <td> France </td> <td> Andorra </td> <td> 0/5 </td> <td> The zero percent rate applies to interest paid: on the credit sale of industrial, commercial, or scientific equipment; on the credit sale of goods or the provision of services by one enterprise to another enterprise; or by a financial institution of one contracting state to a financial institution of the other contracting state. The 5 percent rate applies in other cases. </td> <td> </td> <td> </td> <td> </td> </tr> <tr> <td> Royalties </td> <td> France </td> <td> Andorra </td> <td> 0/5 </td> <td> The zero percent rate applies to royalties paid for the use of, or the right to use, a copyright (excluding royalties for computer software, cinematographic film, or other sound or image recordings). The 5 percent rate applies in other cases. </td> <td> </td> <td> </td> <td> </td> </tr> </tbody> </table>

Andorra - France: 2013 Income Tax Convention and Final Protocol (English Translation)

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Andorra-France Income Tax Treaty Available