EU Updates Its List of Non-cooperative Tax Jurisdictions in October 2026 Review

On 9 October 2026, the Council of the European Union removed Panama and Viet Nam from the EU list of non-cooperative jurisdictions for tax purposes. In the same review, Belize was removed from the grey list after fulfilling its commitments. The blacklist now consists of eight jurisdictions, while both countries move to the grey list pending new reviews by the OECD Global Forum. According to the Council, this update “reflects a positive trend in compliance with international tax good governance standards.”

What is the EU list of non-cooperative tax jurisdictions?

The first EU list was adopted on 5 December 2017. Its aim is not to name and shame countries, but to encourage positive change in their tax legislation. Since 2020, the Council has updated the list twice a year, usually in February and October.

The list has two components:

• Annex I (blacklist): Countries that fail to comply with agreed international tax standards or have not fulfilled their commitments.
• Annex II (grey list or “state of play” document): Jurisdictions that cooperate with the EU but still have pending commitments to reform.

The Code of Conduct Group for business taxation prepares the updates and engages with the jurisdictions concerned. Jurisdictions are assessed against three criteria:

• Tax transparency
• Fair taxation
• Measures against base erosion and profit shifting (BEPS)

Annex I: Panama and Viet Nam removed from the blacklist

In the October 2026 review, the Council removed two jurisdictions from Annex I and added none.

Panama had been on Annex I since February 2020. It has now reformed its harmful foreign-source income exemption regime and has been granted a new review by the OECD Global Forum on its compliance with international standards for exchange of tax information on request. The Council therefore moved Panama to Annex II pending that review.

Viet Nam was added to Annex I in February 2026, after a Global Forum review found that it did not meet the necessary standards for the exchange of tax information on request. After a series of reforms, Viet Nam has also been granted a new review and will remain in Annex II until that review has been carried out.

Following the October 2026 revision, the 8 jurisdictions on Annex I are:

• American Samoa
• Anguilla
• Guam
• Palau
• Russia
• Turks and Caicos Islands
• U.S. Virgin Islands
• Vanuatu

Being on Annex I triggers defensive measures across the EU. As of 1 January 2021, Member States committed to apply legislative measures such as non-deductibility of costs incurred in a listed jurisdiction, controlled foreign company (CFC) rules, withholding tax measures, and limitation of the participation exemption on shareholder dividends. All Member States currently apply at least one of these four measures, and eighteen apply at least two. Member States also apply administrative measures, including reinforced monitoring of transactions and increased risk audits for taxpayers using listed regimes.

In addition, funds from several EU instruments, such as the European Fund for Sustainable Development (EFSD) and the European Fund for Strategic Investments (EFSI), cannot be channelled through entities in listed countries. Since 1 July 2020, EU rules also require reporting of tax schemes involving listed countries.

Annex II: Belize removed, Panama and Viet Nam added

Annex II lists jurisdictions that cooperate with the EU and have committed to address identified deficiencies. Inclusion signals progress under monitoring, not a penalty.

In the October 2026 review:

• Belize was removed from Annex II after receiving a positive rating from the Global Forum on its systems for exchanging tax information on request, meaning it has fulfilled its commitments.
• Panama and Viet Nam were moved from Annex I to Annex II, pending their new Global Forum reviews.

After the review, Annex II includes 10 jurisdictions: British Virgin Islands, Brunei Darussalam, Eswatini, Greenland, Jordan, Montenegro, Morocco, Panama, Türkiye, and Viet Nam.

A quick look back: the February 2026 review

The October decision partly reverses changes made eight months earlier. On 17 February 2026, the Council:

• Added the Turks and Caicos Islands, following concerns raised by the OECD Forum on Harmful Tax Practices regarding the enforcement of economic substance requirements.
• Added Viet Nam, after a Global Forum review on exchange of tax information on request.
• Removed Fiji, Samoa, and Trinidad and Tobago from the list.
• Removed Antigua and Barbuda and Seychelles from the state of play document after they fulfilled their commitments.
• Granted Brunei a six-month extension to reform its foreign-source income exemption regime.

Why these updates matter for global businesses

The 2026 updates show that the EU list of non-cooperative jurisdictions for tax purposes can change as jurisdictions address shortcomings identified through international reviews. Viet Nam’s move from Annex I to Annex II within eight months illustrates how quickly a jurisdiction’s status can shift. These changes can affect more than a jurisdiction’s reputation, as banks, payment providers, and investors may factor EU listings into risk assessments, potentially leading to stricter onboarding and enhanced due diligence.

For global businesses, this makes it important to monitor changes to the EU list, regularly review corporate structures and cross-border payment flows, and assess potential withholding tax and tax deductibility implications under applicable EU rules. Maintaining clear records of business substance and transactions can also help companies respond to due diligence requests and reduce compliance friction.

How BBCIncorp supports international companies

BBCIncorp continues to track policy updates from the EU and the OECD. Our team helps businesses choose jurisdictions that meet international standards and provides full support for incorporation, compliance, accounting, and ongoing corporate management.

With established presences in Hong Kong, Singapore, and Delaware, BBCIncorp helps clients manage multi-jurisdictional operations through a single, secure online platform. Contact our team at service@bbcincorp.com to learn how we can support your business.

To conclude the updates

The October 2026 review shortened the EU blacklist from ten to eight jurisdictions, with Panama and Viet Nam moving to the grey list and Belize leaving it altogether. The next revision of the list is scheduled for February 2027. Businesses should continue to monitor developments and align their structures with internationally recognised standards.