Today I am going to write a series of things that we have seen many times with passive residences that can not be done.
A very usual operation is to make a passive residence to buy a flat or have savings and not declare them. This without a tax residence is basically giving money back to the state of origin. The bank or any entity will have to declare the existence of an account, residence or derivatives, the state of origin will be informed, investigated and a major problem will occur. When you reside in country X fiscally you have the obligation to communicate ALL the assets that you have abroad. A passive does not prevent that.
A different thing is to have a passive and have a company below that constitutes the bulk of the income. In this case it is basically unviable to be resident outside the country where the income is held, so the residence will be discussed and all the assets held in Andorra will have to be taxed with penalties of up to 150%.
In summary, all points must be met. A passive residence living 90 days in the country is useless for all purposes. It has no utility in the current state in which Andorra is. You must reside more than 183 days, have the center of economic interest in the country and the family. The three things. If one is missing, it is a matter of time to have problems.
Having a passive residence as an administrator in the state of origin, residing 90 days or with non-emancipated first-degree relatives outside the country is like having nothing. States have in some cases unlimited time to verify that these conditions are met or not, so the risks are maximum. Certain states argue and demolish residences usually based on these precepts and it is our responsibility that the client knows to act accordingly.