Exit taxes when moving to Andorra: Spain, France and Portugal compared (2026)

Relocating your tax residency to Andorra caps your personal income tax at 10% and removes wealth tax from the equation. But leaving your current country may itself trigger a tax bill — on gains you haven’t realised. Here is how the three main departure countries treat the move in 2026.

Spain: yes — article 95 bis LIRPF

Spain has taxed unrealised gains on departure since 2015. It applies if you were Spanish tax resident for at least 10 of the last 15 tax years and either your total shareholdings exceed €4,000,000 in market value, or you hold more than 25% of a company worth over €1,000,000 (in which case only that stake is taxed). The latent gain flows into the savings tax base at progressive rates of 19% to 30% (the top rate, raised from 28% by Law 7/2024, applies above €300,000). Andorra is outside the EU/EEA, so the favourable 10-year deferral for intra-EU moves does not apply — though a deferral exists for temporary relocations, and Andorra’s tax treaty with Spain qualifies it. Crucially, Andorra is not on Spain’s list of non-cooperative jurisdictions (Order HFP/115/2023, as amended by Order HAC/649/2026 of June 2026), so the punitive tax-haven regime is off the table. Our complete Spain exit-tax guide walks through the deregistration process step by step.

France: yes — article 167 bis CGI, with a procedural trap

France’s exit tax bites if you were French tax resident for 6 of the last 10 years and hold securities worth €800,000 or more (or ≥50% of a company’s profits). The rate is the 30% flat tax. For EU moves the payment is automatically suspended; for Andorra it is not, because the 2013 France–Andorra treaty contains no mutual recovery-assistance clause. Moving to Andorra therefore requires an express deferral request at least 90 days before departure, a French fiscal representative, and guarantees covering the tax. The upside: the deferred tax is cancelled after 2 years (holdings under €2.57M) or 5 years, or upon returning to France — most compliant taxpayers never actually pay it.

Portugal: no general exit tax — with one exception

Portugal levies no general exit tax on individuals. The exception is article 10.º-A of the CIRS: gains previously deferred under fiscal-neutrality reorganisations (share-for-share exchanges, mergers, demergers) become taxable in the year you cease Portuguese residency. If you rolled your company into a holding structure tax-free, that deferred gain crystallises when you leave.

The bigger picture

An exit tax is a one-off toll; Andorran residency is a recurring structure — 10% maximum income tax, no wealth tax, 4.5% VAT, as our Andorra vs Spain tax comparison sets out in detail. Andorra’s zero is real, but it governs what Andorra taxes, not what Spain, France or Portugal tax: the toll is charged by the country you leave, not the one you join, and each has its own rulebook. For portfolios generating substantial annual income the arithmetic usually favours the move within a few years — but the departure itself must be engineered: thresholds checked, deferrals requested on time, guarantees negotiated. Run your recurring numbers with our calculator, and if your holdings are anywhere near these thresholds, speak to a cross-border advisor before booking the moving van.

Sources: art. 95 bis Law 35/2006 (BOE consolidated text); Law 7/2024 (BOE 21-12-2024); Orders HFP/115/2023 and HAC/649/2026 (BOE); art. 167 bis CGI and the 2013 France–Andorra tax treaty (impots.gouv.fr); art. 10.º-A CIRS (Portal das Finanças). Data verified 16 July 2026.