Measure 1: Article 13(1)(h) of the Andorran Corporate Tax Law establishes that the expenses associated to operations directly or indirectly carried out with related entities are not deductible from the tax base of the taxpayer when the income derived from these operations in the jurisdiction of the related entity are exempt or not subject to an income tax with similar characteristics to the Andorran corporate tax, or is subject to the said tax at a nominal rate lower than 40% of the general taxation rate provided for in the Andorran Corporate Tax Law. For these purposes, it will be presumed that there is an income tax similar to the Andorran Corporate Income Tax, with a nominal rate higher than the minimum required, when there is an applicable agreement to avoid double taxation signed between the country where the related entity is resident and the Principality of Andorra. The provisions abovementioned will also be applicable in the cases where the exemption, non-payment or subjection to the minimum nominal rate arises as a result of a different fiscal treatment/classification of the income by the jurisdiction of the related entity with which the operations are carried out. Date Announcement: 13/10/2016 Date Legislation: 20/10/2017 Date entry into force: 16/11/2017. Notwithstanding the date of entry into force, the abovementioned provision will be applicable in relation to fiscal years beginning on or after January 1, 2017. End date (if temporary measure): N/A 

Measure 2: Article 20(1)(a) of the Andorran Corporate Tax Law establishes that dividends or profit-sharing from resident or non-resident entities in the Principality of Andorra, as well as positive income obtained in the transfer of shares or arising from the dissolution of a subsidiary or the separation as a shareholder, are totally exempt from taxation, provided that the non-resident taxpayer is subject, without possibility of exemption, to a tax on income with similar characteristics to the Andorran corporate tax at a nominal rate of at least 40 % of the general Andorran corporate tax rate. In order to establish this substantial similarity, the essential characteristics of the foreign tax are taken into account, as well as if the main purpose of this tax is the taxation of the income obtained by the taxpayer. It will be understood that this requirement is met when the related entity is resident in a country with which the Principality of Andorra has signed an agreement to avoid double taxation and it is applicable to it. Date Announcement: 13/10/2016 Date Legislation: 20/10/2017 Date entry into force: 16/11/2017. Notwithstanding the date of entry into force, the abovementioned provision will be applicable in relation to fiscal years beginning on or after January 1, 2017. End date (if temporary measure): N/A 

Measure 3: Article 21 of the Andorran Corporate Tax Law establishes that positive income obtained abroad through a permanent establishment located outside the territory of the Principality of Andorra are exempted from the tax base when this permanent establishment is subject to a tax with similar characteristics to the Andorran corporate tax at a nominal rate of at least 40 percent of the Andorran general tax rate. In order to establish this substantial similarity, the essential characteristics of the foreign tax are taken into account and whether the main purpose of this tax is the taxation of the income obtained by the taxpayer. This requirement is understood to be fulfilled when the permanent establishment is located in a country with which Andorra has signed an agreement to avoid double taxation. Losses sustained by the permanent establishment are not deductible when the requirements previously set forth are met, except when they have been generated as a result of their activity cessation. Date Announcement: 05/07/2017 Date Legislation: 19/04/2018 Date entry into force: 17/05/2018 End date (if temporary measure): N/A 

Measure 4: Article 38(3) of the Andorran Corporate Tax Law establishes that in the case of dividends received from non-resident companies, taxpayers under the holding regime can only benefit from the exemption when the non-resident investee is subject, without possibility of exemption, to a tax on income similar to the Andorran corporate tax at a nominal rate of at least 40 percent of the Andorran general tax rate. In order to establish this substantial similarity, the essential characteristics of the foreign tax are taken into account, and whether the main purpose of this tax is the taxation of the income obtained by the taxpayer. This requirement is understood to be fulfilled when the investee company is resident in a country with which Andorra has signed an agreement to avoid double taxation and it is applicable to it. If the direct investee company is not subject to a tax with similar characteristics, but its subsidiary company is, the requirement is understood to be fulfilled as regards to the income from the direct investee company which in turns receives from its subsidiary company when those have been subject to a tax with similar characteristics. Date Announcement: 05/07/2017 Date Legislation: 19/04/2018 Date entry into force: 17/05/2018 End date (if temporary measure): N/A