Update of the EU list of non-cooperative jurisdictions for tax purposes

28 Feb 2025

What has changed? 

The Council of the European Union updated the EU list of non-cooperative jurisdictions for tax purposes on 18 February 2025. Specifically, Annex 2 was updated (details are provided below). Annex I, however, has not been changed since 8 October 2024. 

Why is it relevant?

Mainly, in the case of arrangements involving companies from jurisdictions included on the list of non-cooperative jurisdictions for tax purposes, reporting obligations may arise in Romania under DAC6 and public country-by-country reporting rules. 

Companies should therefore review the list and consider the potential implications for transactions with companies located in those jurisdictions.

In detail 

The EU list of non-cooperative jurisdictions for tax purposes is part of the EU’s work to combat tax evasion and abusive tax practices. The list consists of countries that have not fulfilled their commitments to comply with tax good governance criteria within a certain period and countries that have refused to do so. 

Annex I (the “Blacklist”) is the list of countries that do not cooperate with the EU or have not fully fulfilled their commitments in relation to its requirements. Annex I has not been changed since 8 October 2024. The countries included in Annex I are:

  • American Samoa

  • Anguilla

  • Fiji

  • Guam

  • Palau

  • Panama

  • Russia

  • Samoa


  • Trinidad and Tobago

  • US Virgin Islands

  • Vanuatu


Annex II (the “Grey list”) is the list of countries that do not yet comply with all international tax standards but have committed to implementing reforms. Based on the 18 February 2025 updates, those are:

  • Antigua and Barbuda

  • Belize

  • British Virgin Islands

  • Brunei Darussalam 

  • Eswatini

  • Seychelles

  • Turkey

  • Vietnam

The EU will closely monitor the compliance commitments of these countries to ensure implementation of the required measures.

 [Source: Communiqué of the Council of the European Union dated 18 February 2025]

 

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