On 17 February 2026, the Council of the European Union (Economic and Financial Affairs Council – ECOFIN) adopted conclusions updating the EU list of non-cooperative jurisdictions for tax purposes (Annex I) and the “state of play” for cooperative jurisdictions with pending commitments (Annex II, the so-called “grey list”).
The revised Annexes will take effect upon publication in the Official Journal of the European Union.
The newly updated EU list of non-cooperative jurisdictions (Annex I) now includes the following territories, with additions highlighted in bold for clarity:
- American Samoa
- Anguilla
- Guam
- Palau
- Panama
- Russia
- Turks and Caicos Islands
- US Virgin Islands
- Vanuatu
- Viet Nam
(At the same time, Fiji, Samoa, and Trinidad and Tobago were removed from Annex I.)
What’s Next?
The EU is expected to update this list again in October 2026, continuing to monitor jurisdictions’ compliance with international tax standards.
Cyprus’ Defensive Measures
Cyprus has introduced defensive measures targeting payments to EU blacklisted jurisdictions and low-tax jurisdictions, including withholding tax / deductibility restrictions depending on payment type and circumstances.
Impact on EU Mandatory Disclosure Rules (DAC6)
The revised EU blacklist is also relevant for DAC6 purposes. In particular, Hallmark C1(b)(ii) may be triggered where there is a tax-deductible cross-border payment between associated enterprises and the recipient is tax resident in a jurisdiction included in Annex I. In these cases, the main benefit test does not apply.
How George Kaimakliotis & Co Ltd Can Help
At George Kaimakliotis & Co Ltd, we assist clients in assessing the implications of the updated EU blacklist, including the application of Cyprus defensive measures to outbound payments and the identification of potential reporting obligations under DAC6, helping ensure compliance and reducing execution risk.
You may reach us info@kaimakliotis.com.cy for support and guidance.
