Explanatory note

The Schedule to this Order contains a Convention (“the Arrangements”) between the United Kingdom of Great Britain and Northern Ireland and the Principality of Andorra for the elimination of double taxation with respect to taxes on income and on capital gains, the prevention of tax evasion and avoidance, and assisting international tax enforcement.

The Schedule also contains Note No: 03/2025 to the Ministry of Foreign Affairs of the Principality of Andorra, dated 11 June 2025 in which His Britannic Majesty’s Embassy proposes the correction of the Convention and the replying Note Verbale from the Ministry of Foreign Affairs of the Principality of Andorra, dated 12 June 2025, which together constitute an agreement correcting the Convention. The text of the Convention appended has therefore been corrected.

This Order brings the Arrangements into effect.

Article 1 provides for citation and Article 2 makes a declaration as to the effect and contents of the Arrangements.

The Arrangements aim to eliminate the double taxation of income and gains arising in one country and paid to the residents of the other country. This is done by allocating the taxing rights that each country has under its domestic law over the same income and gains, and by providing relief from double taxation. There are also specific measures which combat discriminatory tax treatment and provide for assistance in international tax enforcement.

The Arrangements will enter into force on the date of the later of the notification by each country of the completion of its domestic procedures and will take effect in each territory in accordance with Article 28 of the Convention.

The date of entry into force will, in due course, be published in the London, Edinburgh and Belfast Gazettes.

A Tax Information and Impact Note has not been produced for the Order as it gives effect to a double taxation agreement. Double taxation agreements impose no obligations on taxpayers, rather they seek to eliminate double taxation and fiscal evasion.