Líder Legal has published an in-depth report analysing Andorra’s evolving tax framework following the approval of the second Omnibus Law (Llei Òmnibus 2) on 22 January.
In this feature, Carlota Pastora, Managing Partner of Carlota Pastora Business Law Firm, provides a strategic assessment of the reform and its implications for high-net-worth individuals, investors and international families considering relocation to Andorra.
The report positions 2026 as a structural turning point: not because Andorra’s tax system has been transformed, but because access to its residency regime has become significantly more selective.
“Relocation now requires genuine tax structuring, analysis of the country of origin and absolute compliance.”
1. Tax Outlook for Andorra in 2026 After Llei Òmnibus
How would you describe Andorra’s tax outlook for 2026 following the approval of Llei Òmnibus 2? What opportunities and challenges do you identify for investors and companies in terms of wealth planning, corporate structuring and relocation, particularly considering the new investment requirements and non-refundable payments introduced by the reform?
Andorra’s tax outlook for 2026 remains fundamentally solid. Llei Òmnibus 2 has not altered the core tax system. Moderate tax rates remain in place, as does the absence of wealth tax, inheritance tax and gift tax. The structure continues to be clear and attractive for those seeking serious wealth planning aligned with international standards.
However, the reform introduces a more demanding access framework. Investment thresholds have increased, and the deposits of €50,000 for the main applicant and €12,000 per dependent have become non-refundable payments. This creates a more exclusive and stable medium-term environment, attracting residents with more homogeneous and committed profiles. From a wealth planning and relocation perspective, this provides a degree of reassurance compared to regulatory environments in other jurisdictions that may be more unpredictable.
That said, the challenges are evident. The initial financial outlay is significantly higher, and the obligation to demonstrate genuine economic ties eliminates quick or low-cost options. For those who value long-term stability and discretion, this change can be considered logical. However, individuals prioritising convenience or minimal effort will likely look to alternative destinations.
2. Impact on Andorra’s Passive Residency (“Golden Visa”) Programme
What impact does Llei Òmnibus 2 have on Andorra’s residency-by-investment programme (passive residency)? How do you see the future of Andorra’s “Golden Visas”? Does it remain competitive compared to other European programmes, or has it become a more exclusive and selective option?
Llei Òmnibus 2 has significantly raised the requirements for accessing Andorra’s passive residency programme, consolidating its exclusive character. The new investment thresholds, together with the non-refundable deposits payable to the Andorran Financial Authority, reflect a more restrictive and selective approach aimed at attracting individuals with substantial wealth and a genuine long-term commitment to the country.
This reform positions Andorra’s “Golden Visa” as a far more exclusive option, distancing it from more accessible entry schemes. Andorra continues to stand out due to its proximity to Spain and France, a predictable tax system and an exceptionally high quality of life. However, it is no longer the simplest or most agile entry point into Europe.
While other European jurisdictions have also tightened their regimes, Andorra differentiates itself through discretion and a long-term quality-of-life focus. It is becoming a premium alternative for those who value stability and exclusivity over ease or speed.
3. Opportunities and Risks for Clients Considering Relocation to Andorra
What opportunities and risks do you identify for clients interested in relocating to Andorra?
For individuals considering relocation to Andorra, the opportunities centre on fiscal stability, legal certainty and a regulatory environment that encourages long-term wealth structuring. The reform may also contribute to a more homogeneous and integrated resident community, fostering a more stable social and professional ecosystem.
In terms of risks, I would describe them more as challenges. The need to demonstrate genuine economic ties removes the possibility of using Andorra as a simple “tax stop” without real commitment. This requires more detailed planning and a strategic approach to ensure full compliance with legal and tax requirements. Additionally, the current international transparency framework, including automatic exchange of information, leaves little room for residency structures that are not fully aligned and properly documented.
Ultimately, relocation to Andorra is ideal for profiles that value stability, genuine commitment and well-structured planning. It is essential to conduct an honest assessment of personal and family objectives to ensure alignment between what Andorra offers today and the applicant’s long-term expectations.
Andorra: Competitive Taxation Under Greater Scrutiny
As highlighted in the Líder Legal report, Andorra represents a distinctive model within the European tax landscape: lower volume, stronger filtering mechanisms and a clear strategic bet on long-term stability.
The expansion of automatic exchange of information with the European Union – including, from 2026, crypto-assets, electronic money and digital currencies – has increased scrutiny and eliminated standardised relocation approaches. According to Carlota Pastora, this shift should not be viewed as a deterrent, but rather as a strategic repositioning.
The firm’s approach for 2026 reflects this evolution:
- Full-spectrum cross-border tax planning
- Preventive structuring
- Succession modelling and international wealth coordination
- Integration of artificial intelligence tools to simulate tax and inheritance scenarios, always under strict human supervision
The focus is not on transaction volume, but on depth of advisory and long-term alignment with client objectives.
Looking Ahead to 2026
With over 15 years of experience in international tax advisory, Carlota Pastora continues to position the firm as a strategic partner for Iberian and international clients navigating Andorra’s evolving regulatory environment.
The message is clear: Andorra remains competitive – but selective.
For families and investors seeking stability, predictability and serious wealth planning within a transparent international framework, the Principality continues to offer a compelling long-term proposition.
