If you are moving a company with goods to the EU, the decision is not whether the referendum will be favorable, but whether the 1990 customs agreement will remain the applicable framework during the move. According to the news, a “no” vote does not by itself eliminate that agreement; the risk arises if the provisional application of the association replaces its provisions before the consultation.
- The 1990 customs agreement has its own regime: it does not disappear automatically upon rejecting the association, provided it is not formally denounced or replaced.
- The report cites Article 21: denunciation can be made with six months’ notice.
- If the association integrates customs matters and produces effects before the referendum, a subsequent “no” might not automatically restore the previous agreement.
- For the relocation, what matters is verifying which text governs each date, not the political rhetoric.
What the current agreement protects and what is not lost just by a “no”
The customs agreement affects those who move goods, not necessarily a residency without activity or a holding company. If a company imports, exports, re-exports, or maintains stock in transit, it needs to know which rule governs its shipments, the origin of the products, and the required proofs. The original report points out that a negative result in the referendum does not automatically equate to the loss of the 1990 agreement. That framework can only cease to have effect through the corresponding legal procedures, including the six-month notice for denunciation cited in the text.
This continuity, however, cannot be presented as an absolute guarantee. The report identifies a decisive distinction: if the rejection occurs before another regime replaces the agreement, the previous framework remains. If the rejection occurs after a substitution has already been applied, automatic recovery is not guaranteed. For a high-net-worth profile, this turns the debate into a problem of dates and legal effects, not one of preference for yes or no.
The real risk: provisional application and substitution before the referendum
The article suggests that the association agreement could integrate customs relations into a broader framework. If those replacement provisions enter into force before the consultation, the company moves from an independent regime to a regime linked to the new treaty. In that case, a “no” does not simply resolve continuity: it would be necessary to determine which parts of the 1990 agreement remain available, which are displaced, and whether the Andorran or European legal system establishes a reactivation mechanism.
The proposed calendar mentioned in the report cannot be taken as certainty either. It cites a referendum scenario between three and six months after the investiture, with the possibility of September 2027 if elections were in March and the investiture in April. That date, according to the text itself, is part of a political strategy. What affects the move is whether the provisional application is approved, when, and with what scope.
Comparative scenarios for a company with EU operations
| Situation | Status of the customs agreement | Business risk |
|---|---|---|
| Rejection of association before substitution | The 1990 agreement remains in force if not denounced or displaced. | Planning with current framework, but contracts must foresee changes. |
| Formal denunciation | Requires procedure and, according to the report, six months’ notice. | Predictable schedule: stock, transport, suppliers, and clauses. |
| Association provisionally applied | Could replace the customs part if the provisions produce effects. | Greater uncertainty regarding customs and origin rules. |
| Rejection after substitution | The report warns that the old agreement would not be automatically restored. | Risk of commercial discontinuity and renegotiation. |
Relocation, self-employment, and the limits of the news
If the relocation is structured through an active company, the requirements for self-employed residency operate on a different level: ownership stake greater than 34%, administrative and effective management position, 183 days of stay per year, and a non-refundable deposit of 50,000 euros, with exceptions for certain projects, according to the reference data provided by Law 2/2026. These requirements condition the authorization but do not resolve the scope of the customs agreement. It also cannot be deduced from the report that the association modifies VAT (IGI), banking, or social security: those aspects require verification in official texts.
Corporate taxation may still be an important factor in the moving decision. Based on reference data, typical maximum rates are 10% PIT, 10% corporate tax, and 4.5% general IGI. However, a wealth analysis must separate residency, taxes, market access, logistics, and contractual liability. To review the corporate side, you can consult creating a company in Andorra; for tax burden, taxes in Andorra.
Illustrative example to gauge exposure
The report does not provide economic impact figures. To organize the decision, a visible formula with hypothetical assumptions can be applied: exposure = billing to the EU × percentage of volume sensitive to the customs regime × days of disruption ÷ 365. With a company billing 2,000,000 euros, 20% of sensitive operations, and 45 days of uncertainty, the illustrative exposure would be 49,315 euros before additional expenses. The calculation is not a prediction: it shows why a company with narrow margins or committed deliveries needs legal clarity before moving.
What to check before executing the move
Before moving goods, companies, or family members, it is advisable to verify four documents: the 1990 customs agreement and its denunciation mechanism; the association agreement and the clauses on customs matters; the decision on provisional application, if it exists; and the internal development regulations published in Andorra. If any date, scope, or consequence does not appear in the BOPA, in the legal portal, or in EU instruments, it should be flagged as pending. Uncertainty is legitimate; affirmation without a source is not.
If your structure includes goods operations with the EU, the practical conclusion is to protect contracts, inventory, and logistics schedules against a possible substitution, without assuming that a “no” will destroy the existing framework. If your move is passive or without goods, the customs agreement may be an indirect risk, but the priority will remain residency eligibility and global income taxation.
Sources
- Laveulliure.ad: original news regarding the customs agreement and the association with the EU
- Official Gazette of the Principality of Andorra
- Government of Andorra
- Taxes
- Andorran Financial Authority
- CASS
- Andorran Legal Portal
To review a move involving a company, family, or assets, you can request a case review at AndorraWay.