Country-by-country (CbC) reporting and notification requirements have been enacted in the tax law in Andorra.
Andorra’s corporate income tax law was amended with the enactment of the reform law 6/2018 (April 2018). One measure aims at aligning the tax rules in Andorra with OECD’s base erosion and profit shifting (BEPS) project—specifically BEPS Actions 5 and 13. Another measure adapts Andorran law to reflect the EU’s Economic and Financial Affairs Council Code of Conduct.
The BEPS-related measures, enacted under reform law 6/2018, include implementation of the following CbC requirements:
It has been observed that Andorra has persisted in adapting its tax laws to follow to the OECD’s recommendations and best practices. However, the new measures only address a portion of the BEPS Action 13 recommendations—there are no Master file or Local file requirements. However, tax professionals expect further amendments could follow.
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