Personal holding companies are not transparent for tax purposes.

Warning : a company is resident in Andorra if its effective management is in Andorra.

If the effective management of a personal holding company is in Andorra, the company is subject to corporation tax on worldwide profits and capital gains.

What goes on inside the personal holding company is not a matter for the IRPF if the entity is not managed in or from Andorra.

Whether the company is effectively managed within andorra or not is a complex matter.