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Andorra: Country-by-country reporting and notification rules

Andorra: CbC reporting and notification rules

Country-by-country (CbC) reporting and notification requirements have been enacted in the tax law in Andorra.


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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:

  • The CbC filing requirements in Andorra generally follow the filing obligations put forward in the BEPS Action 13 recommendations, effective for fiscal years beginning on or after 1 January 2018. 
  • CbC reporting is required within the 12-month period following the end of the fiscal (tax) year.
  • The due date for filing a CbC notification is the deadline provided for filing a corporate income tax return for the reporting fiscal year. The requirements for the content of the CbC notification generally follow the recommendations of BEPS Action 13. 
  • The penalties for failing to comply with the CbC requirements (either CbC reporting or CbC notification) are €1,000 for the first offence and €3,000 for subsequent offences. 

KPMG observation

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.


For more information, contact a tax professional with KPMG’s Global Transfer Pricing Services practice:

Daniel Bourdages | +34 9325 32900 |

Elisenda Monforte Vila | +34 9325 42311 |

Andreu Gifre Monreal | +34 9325 32900 | 

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