Panama and Viet Nam leave the EU tax blacklist; eight jurisdictions remain

On 9 October 2026 the Council of the EU, meeting in Luxembourg as the Economic and Financial Affairs Council, adopted conclusions revising the EU list of non-cooperative jurisdictions for tax purposes (Council document 13854/26). The Council removed Panama and Viet Nam from Annex I, the list proper, and moved them to Annex II, where they stay under monitoring. The revision matters to groups with counterparties or vehicles in listed jurisdictions, and to any compliance policy that refers to the list.

What the rules say

The list is published as annexes to Council conclusions, and the two annexes do different work. Annex I is the list of non-cooperative jurisdictions. Annex II is what the Council calls a "state of play" document, covering jurisdictions that do not yet meet all international tax standards but have committed to reform.

The criteria, agreed by member states in November 2016, are tax transparency, fair taxation and the G20/OECD minimum standards against base erosion and profit shifting (BEPS). The conclusions give a reason for each listing. American Samoa and Guam do not apply automatic exchange of financial information. Palau has not signed and ratified the OECD Multilateral Convention on Mutual Administrative Assistance. Russia keeps a harmful preferential regime for international holding companies, and the US Virgin Islands have no automatic exchange and several harmful preferential regimes. Anguilla, the Turks and Caicos Islands and Vanuatu are cited for enabling offshore structures without real economic substance; Anguilla is also not rated at least "largely compliant" on exchange of information on request.

The European Commission said Panama and Viet Nam were moved to Annex II pending an in-depth review of their exchange of information frameworks by the Global Forum. For Viet Nam the listing was brief: the Council's timeline shows it had been added to Annex I only on 17 February 2026. Vanuatu's progress on transparency was recognised, but it stays on the list because of an outstanding concern in another area.

Belize left Annex II altogether. Annex II now has 10 entries: the British Virgin Islands, Brunei Darussalam, Eswatini, Greenland, Jordan, Montenegro, Morocco, Panama, Türkiye and Viet Nam.

The consequences of listing are set out on the Council's policy page, and they were introduced in two stages. Since December 2017 member states have agreed to apply at least one administrative measure: reinforced monitoring of transactions, or increased audit risk for taxpayers benefiting from, or using schemes involving, listed regimes. From 1 January 2021 each should apply at least one of four legislative measures: non-deductibility of costs incurred in listed jurisdictions, controlled foreign company rules, withholding tax measures, or limits on the participation exemption for dividends. EU funds under the European Fund for Sustainable Development, the European Fund for Strategic Investments and the external lending mandate cannot be channelled through entities in listed jurisdictions, and EU rules on tax intermediaries add reporting requirements for schemes that involve them.

Who is affected

The Council lists the United Arab Emirates, Mauritius, the Seychelles, Singapore and Hong Kong among jurisdictions that cooperate and have no pending commitments. For groups based there, any effect comes through their dealings with places that are listed or monitored.

Those dealings can still matter. A group may hold assets through a Panama or British Virgin Islands company, or source goods from Viet Nam. Where an EU company pays such an entity, or an EU bank or fund reviews it, the jurisdiction's status on the list can bear on deductibility, withholding and due diligence.

Key dates

• 17 February 2026: Viet Nam added to Annex I.
• 9 October 2026: Council conclusions adopted; Panama and Viet Nam moved to Annex II.
• 22 December 2026: deadline for Brunei Darussalam to complete reform of its foreign-source income exemption regime.
• 15 February 2027: date by which the British Virgin Islands has committed to request and obtain an in-depth Global Forum review.
• February 2027: next revision of the list, according to the Council's policy page. Updates have been limited to twice a year since 2020.

What it means in practice

Take a hypothetical Mauritius holding company whose Panama subsidiary invoices service fees to a German group company. While Panama was on Annex I, the German payer could be exposed to whichever defensive measure Germany applies to listed jurisdictions. With Panama now on Annex II, those Annex I measures should fall away, though on the timetable of national law rather than on the date of the Council decision. Panama also remains under monitoring, and a negative outcome from its Global Forum review could put it back on the list.

What we do not yet know

The Council has not published dates for the Global Forum reviews of Panama and Viet Nam, and the EU pages do not say when each member state will stop applying its defensive measures to the two jurisdictions. The record also contains a small discrepancy: the Council's own timeline gives the removal as 8 October 2026, a day before the date on the conclusions.