EU list of non-cooperative jurisdictions

EU tax blacklist 2026: the full list and every change since 2017

Updated 11 November 2026Council update of 9 October 202643 jurisdictions in the record
The short answer

Eight jurisdictions are on the EU blacklist (Annex I) after the Council update of 9 October 2026: American Samoa, Anguilla, Guam, Palau, Russia, Turks and Caicos Islands, the US Virgin Islands and Vanuatu.

Panama and Viet Nam came off on that date. Ten more sit on the grey list (Annex II), among them the British Virgin Islands.

Annex I today 8 jurisdictions on the EU blacklist after 9 October 2026 Down from 17 on the first list in December 2017. 36 jurisdictions have been on it at least once across 27 Council revisions.

You're probably here because a bank, a client or an accountant mentioned the list, and you need to know whether it touches you. The honest answer is usually no. The EU list is short, it changes twice a year, and what it does is make EU countries treat payments to listed places differently. It doesn't ban anyone. Below is the list as it stands, every change since the first one, and what a listing really costs a company.

Key takeaways

  • Annex I (the blacklist) has 8 names after 9 October 2026; Annex II (the grey list) has 10.
  • Panama left Annex I after almost seven years, and Viet Nam after eight months.
  • Each member state applies at least one defensive measure to listed places: blocked deductions, CFC taxation, withholding tax or no participation exemption.
  • Payments to a listed place can make an arrangement reportable under DAC6.
  • Annex II carries no measures; it is a list of promises with deadlines.
  • The FATF lists are a different thing, and they are what most bank questions are really about.
Chapter 1

The EU list of non-cooperative jurisdictions today

The Council of the EU adopted the current list on 9 October 2026 (Council conclusions, 9 October 2026). Each name comes with the reason, which tells you what the place would have to change to come off.

  • American SamoaNo automatic exchange of financial account information, and no commitment to fix itOn the list since 5 December 2017
  • AnguillaExchange of information rating below "largely compliant"; economic substance rules not enforcedOn the list since 4 October 2022 (listed before, Oct 2020 to Oct 2021)
  • GuamNo automatic exchange of financial account informationOn the list since 5 December 2017
  • PalauHas not signed and ratified the OECD convention on mutual assistance in tax mattersOn the list since 18 February 2020 (listed before, Dec 2017 to Oct 2018)
  • RussiaHarmful regime for international holding companiesOn the list since 14 February 2023
  • Turks and Caicos IslandsEconomic substance rules not effectively enforcedOn the list since 17 February 2026 (listed before, Oct 2022 to Feb 2024)
  • US Virgin IslandsNo automatic exchange; three harmful tax regimesOn the list since 13 March 2018
  • VanuatuOffshore structures without real economic substanceOn the list since 12 March 2019

Annex II, the grey list

These ten are cooperative but have made commitments the EU is still waiting on. Two sit in more than one section.

Automatic exchangeTürkiye, Jordan, Montenegro
Exchange on requestBritish Virgin Islands, Montenegro, Panama, Viet Nam
Harmful tax regimesBrunei Darussalam, Eswatini
Country-by-country reportingGreenland, Jordan, Morocco, Viet Nam

What changed on 9 October 2026 is set out in the Code of Conduct Group report of 25 September 2026: no new listings, Panama and Viet Nam delisted and moved to Annex II, Belize removed from Annex II.

1
Key takeaway

Eight on the blacklist, ten on the grey list, and only the first carries consequences.

Chapter 2

Every jurisdiction ever listed, with dates

This is the complete record of Annex I since 5 December 2017, plus everyone on Annex II today. Every period links to the Official Journal text that added or removed it. Sort by any column, or narrow it down.

Showing all 43

Annex I periods from the Council conclusions of 5 December 2017 and each later revision as published in the Official Journal. Dates are the revision dates the Council itself lists. Time on Annex I counts whole months to 9 October 2026. Status and reasons: Council conclusions of 9 October 2026.
Reason or outcomeStatus source
American SamoaAnnex IDec 2017 to today8 y 10 mNo automatic exchange of financial account information, and no commitment to fix itCouncil, 9 Oct 2026
AnguillaAnnex IOct 2020 to Oct 2021
Oct 2022 to today
5 y 0 mExchange of information rating below "largely compliant"; economic substance rules not enforcedCouncil, 9 Oct 2026
GuamAnnex IDec 2017 to today8 y 10 mNo automatic exchange of financial account informationCouncil, 9 Oct 2026
PalauAnnex IDec 2017 to Oct 2018
Feb 2020 to today
7 y 6 mHas not signed and ratified the OECD convention on mutual assistance in tax mattersCouncil, 9 Oct 2026
RussiaAnnex IFeb 2023 to today3 y 8 mHarmful regime for international holding companiesCouncil, 9 Oct 2026
Turks and Caicos IslandsAnnex IOct 2022 to Feb 2024
Feb 2026 to today
2 y 0 mEconomic substance rules not effectively enforcedCouncil, 9 Oct 2026
US Virgin IslandsAnnex IMar 2018 to today8 y 7 mNo automatic exchange; three harmful tax regimesCouncil, 9 Oct 2026
VanuatuAnnex IMar 2019 to today7 y 7 mOffshore structures without real economic substanceCouncil, 9 Oct 2026
British Virgin IslandsAnnex IIFeb 2023 to Oct 20230 y 8 mExchange of information on request: to be granted an in-depth review by 15 February 2027Council, 9 Oct 2026
BruneiAnnex IINever on Annex I0Foreign-source income exemption reform, extended to 22 December 2026Council, 9 Oct 2026
EswatiniAnnex IINever on Annex I0Special economic zone regime awaiting final assessmentCouncil, 9 Oct 2026
GreenlandAnnex IINever on Annex I0Country-by-country reporting fixes due in autumn 2026Council, 9 Oct 2026
JordanAnnex IINever on Annex I0Automatic exchange and country-by-country reporting fixes due in 2026Council, 9 Oct 2026
MontenegroAnnex IINever on Annex I0Automatic exchange fixes due in 2026; waiting for an in-depth reviewCouncil, 9 Oct 2026
MoroccoAnnex IINever on Annex I0Country-by-country reporting fixes due in autumn 2026Council, 9 Oct 2026
PanamaAnnex IIDec 2017 to Jan 2018
Feb 2020 to Oct 2026
6 y 9 mExchange of information on request: waiting for an in-depth reviewCouncil, 9 Oct 2026
TürkiyeAnnex IINever on Annex I0Automatic exchange not yet working with one member stateCouncil, 9 Oct 2026
Viet NamAnnex IIFeb 2026 to Oct 20260 y 8 mExchange of information review pending; country-by-country reporting fixes due by autumn 2027Council, 9 Oct 2026
Antigua and BarbudaNot listedOct 2023 to Oct 20241 y 0 mRemoved after meeting the criteriaCouncil, 9 Oct 2026
ArubaNot listedMar 2019 to May 20190 y 2 mRemoved after meeting the criteriaCouncil, 9 Oct 2026
BahamasNot listedMar 2018 to May 2018
Oct 2022 to Feb 2024
1 y 6 mRemoved after meeting the criteriaCouncil, 9 Oct 2026
BahrainNot listedDec 2017 to Mar 20180 y 3 mRemoved after meeting the criteriaCouncil, 9 Oct 2026
BarbadosNot listedDec 2017 to Jan 2018
Mar 2019 to May 2019
Oct 2020 to Feb 2021
0 y 7 mRemoved after meeting the criteriaCouncil, 9 Oct 2026
BelizeNot listedMar 2019 to Nov 2019
Oct 2023 to Feb 2024
1 y 0 mRemoved after meeting the criteriaCouncil, 9 Oct 2026
BermudaNot listedMar 2019 to May 20190 y 2 mRemoved after meeting the criteriaCouncil, 9 Oct 2026
Cayman IslandsNot listedFeb 2020 to Oct 20200 y 8 mRemoved after meeting the criteriaCouncil, 9 Oct 2026
Costa RicaNot listedFeb 2023 to Oct 20230 y 8 mRemoved after meeting the criteriaCouncil, 9 Oct 2026
DominicaNot listedMar 2019 to Jun 2019
Feb 2021 to Oct 2021
0 y 11 mRemoved after meeting the criteriaCouncil, 9 Oct 2026
FijiNot listedMar 2019 to Feb 20266 y 11 mRemoved after meeting the criteriaCouncil, 9 Oct 2026
GrenadaNot listedDec 2017 to Jan 20180 y 1 mRemoved after meeting the criteriaCouncil, 9 Oct 2026
MacaoNot listedDec 2017 to Jan 20180 y 1 mRemoved after meeting the criteriaCouncil, 9 Oct 2026
Marshall IslandsNot listedDec 2017 to Mar 2018
Mar 2019 to Oct 2019
Feb 2023 to Oct 2023
1 y 6 mRemoved after meeting the criteriaCouncil, 9 Oct 2026
MongoliaNot listedDec 2017 to Jan 20180 y 1 mRemoved after meeting the criteriaCouncil, 9 Oct 2026
NamibiaNot listedDec 2017 to Nov 20180 y 11 mRemoved after meeting the criteriaCouncil, 9 Oct 2026
OmanNot listedMar 2019 to Oct 20201 y 7 mRemoved after meeting the criteriaCouncil, 9 Oct 2026
Saint Kitts and NevisNot listedMar 2018 to May 20180 y 2 mRemoved after meeting the criteriaCouncil, 9 Oct 2026
Saint LuciaNot listedDec 2017 to Mar 20180 y 3 mRemoved after meeting the criteriaCouncil, 9 Oct 2026
SamoaNot listedDec 2017 to Feb 20268 y 2 mRemoved after meeting the criteriaCouncil, 9 Oct 2026
SeychellesNot listedFeb 2020 to Oct 2021
Oct 2023 to Feb 2024
2 y 0 mRemoved after meeting the criteriaCouncil, 9 Oct 2026
South KoreaNot listedDec 2017 to Jan 20180 y 1 mRemoved after meeting the criteriaCouncil, 9 Oct 2026
Trinidad and TobagoNot listedDec 2017 to Feb 20268 y 2 mRemoved after meeting the criteriaCouncil, 9 Oct 2026
TunisiaNot listedDec 2017 to Jan 20180 y 1 mRemoved after meeting the criteriaCouncil, 9 Oct 2026
United Arab EmiratesNot listedDec 2017 to Jan 2018
Mar 2019 to Oct 2019
0 y 8 mRemoved after meeting the criteriaCouncil, 9 Oct 2026
2
Key takeaway

Most places leave within a year or two; a few, like Fiji and Samoa, stayed for years.

Chapter 3

How the blacklist grew and shrank

The list was born at 17, halved within two months as places made commitments, then filled up again in March 2019 when those commitments fell due. The count after each revision:

Jurisdictions on Annex I after each of the 27 Council revisionsFrom 17 in December 2017 to 5 in late 2018, 15 in March 2019, 16 in 2023 and 8 on 9 October 2026.0510155 December 2017: 17 jurisdictions1723 January 2018: 9 jurisdictions913 March 2018: 9 jurisdictions925 May 2018: 7 jurisdictions72 October 2018: 6 jurisdictions66 November 2018: 5 jurisdictions54 December 2018: 5 jurisdictions512 March 2019: 15 jurisdictions1522 May 2019: 12 jurisdictions1214 June 2019: 11 jurisdictions1117 October 2019: 9 jurisdictions98 November 2019: 8 jurisdictions85 December 2019: 8 jurisdictions818 February 2020: 12 jurisdictions126 October 2020: 12 jurisdictions1222 February 2021: 12 jurisdictions125 October 2021: 9 jurisdictions924 February 2022: 9 jurisdictions94 October 2022: 12 jurisdictions1214 February 2023: 16 jurisdictions1617 October 2023: 16 jurisdictions1620 February 2024: 12 jurisdictions128 October 2024: 11 jurisdictions1118 February 2025: 11 jurisdictions1110 October 2025: 11 jurisdictions1117 February 2026: 10 jurisdictions109 October 2026: 8 jurisdictions8201820192020202120222023202420252026

Count of Annex I jurisdictions after each of the 27 revisions from 5 December 2017 to 9 October 2026, from the Official Journal texts linked in the record above.

Two things stand out. Removals usually follow a concrete fix: a new exchange agreement, a repealed regime, a better peer review rating. And the places that stay longest are the ones that never made a commitment at all, like American Samoa and Guam, on every version since 2017.

3
Key takeaway

A listing ends when the place fixes the named problem, usually within a year or two.

Chapter 4

What being on the EU blacklist means for a company

%

Nothing changes inside the listed country. What changes is how EU countries treat money that flows to it. Since 1 January 2021 every member state applies at least one of four defensive measures agreed in the Council's guidance of November 2019:

Measure 1No deductionInterest, royalties and service fees paid to a company in a listed place stop being deductible for the EU payer.
Measure 2CFC taxationThe income of a company in a listed place can be taxed in the hands of its EU parent, with fewer exemptions.
Measure 3Withholding taxA higher or special withholding tax on interest, royalties or fees paid to the listed place.
Measure 4No participation exemptionDividends from a subsidiary in a listed place lose the usual tax-free treatment.

A worked example: Ireland

Ireland's Revenue uses all four routes in some form: companies disclose interest, royalty and dividend dealings with listed places on their tax return, certain CFC exemptions are switched off, withholding tax applies to interest, royalties and distributions to listed places since 2024, and the participation exemption is not available for a subsidiary resident in one.

DAC6 reporting

Under the EU's mandatory disclosure rules, a deductible cross-border payment between related companies to a recipient in a listed jurisdiction is a reportable hallmark on its own (Directive 2018/822, hallmark C.1(b)(ii)). Advisers or the taxpayer must file it.

Banks

No EU rule tells a bank to close an account because a country is listed. But the European Banking Authority's risk factor guidelines name the EU tax list among the sources banks use to judge a country's tax transparency, so expect more questions, not a refusal.

Where do you live? pick it

4
Key takeaway

The cost falls on payments from the EU: lost deductions, extra tax and a report.

Chapter 5

How the jurisdictions we form companies in stand

None of the places Heirson forms companies in is on Annex I today. Eleven have been at some point, mostly briefly, and two sit on Annex II. Malta, Cyprus, Bulgaria and Estonia are EU members, which the list doesn't cover.

Each tax guide explains what the listing history means for a company there today. For the full picture of where companies pay little or no tax, see our tax haven guide.

5
Key takeaway

No Heirson jurisdiction is blacklisted; the BVI and Panama are on the grey list.

Chapter 6

Lists that are often confused with it

EUFATF
  1. FATFGrey list and black listAbout anti-money-laundering supervision, updated three times a year. The BVI is under FATF increased monitoring as of October 2026 while off the EU blacklist.
  2. European CommissionHigh-risk third countries for money launderingA separate EU list under the anti-money-laundering rules. Banks must apply enhanced checks to it by law.
  3. Member statesNational listsSeveral EU countries keep their own lists for tax rules, which can name places the EU list does not. Check the one where the payer sits.
  4. OECDPeer review ratingsNot a list, but the Global Forum ratings that most EU listings and delistings are based on.
6
Key takeaway

Tax list, money-laundering lists and national lists are separate; check the one that applies.

Chapter 7

EU tax blacklist questions, answered

?!
Which countries are on the EU tax blacklist in 2026?
Eight, after the Council update of 9 October 2026: American Samoa, Anguilla, Guam, Palau, Russia, Turks and Caicos Islands, the US Virgin Islands and Vanuatu.
What is the EU grey list?
Annex II of the same Council conclusions. It names cooperative jurisdictions that have promised to fix something by a deadline. Ten are on it now, including the British Virgin Islands and Panama. Being there carries no defensive measures.
When is the EU list updated?
No more than twice a year. Since 2020 the Council has revised it every February and October, so the next update is expected in February 2027.
Was Panama removed from the EU blacklist?
Yes. The Council removed Panama from Annex I on 9 October 2026 after its reform of the foreign-source income exemption, and moved it to Annex II until the Global Forum reviews its exchange of information.
Are the British Virgin Islands on the EU blacklist?
No. The British Virgin Islands were on Annex I from February to October 2023. Today they are on Annex II, committed to an in-depth exchange of information review.
Is the EU list the same as the FATF grey list?
No. The EU list is about tax transparency and fair taxation. The FATF lists are about anti-money-laundering supervision. A country can be on one and not the other.
What happens to a company in a blacklisted country?
Its own country's law doesn't change, but EU countries treat payments to it differently: costs may not be deductible, withholding tax may apply, the income may be taxed under CFC rules and advisers must report certain arrangements under DAC6.
Can EU countries be on the list?
No. The list covers non-EU jurisdictions only. Member states are assessed through the EU's own Code of Conduct work instead.

Changelog

  • 11 November 2026: first published, with the Council conclusions of 9 October 2026 (published in the Official Journal on 16 October 2026), the Code of Conduct Group reports of February and September 2026 (February, September) and every earlier revision since 5 December 2017. Next expected update: February 2027.
Choosing a jurisdiction

A company in a place no EU list holds against you.

Compare the jurisdictions we form companies in, with every fee and every list shown up front.