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Panama And Vietnam Exit The EU Tax Blacklist After Reform Pledges

Panama City: Panama and Vietnam are no longer on the EU tax blacklist, after finance ministers in the Economic and Financial Affairs Council adopted an update to the Union’s list of non-cooperative jurisdictions on 9 October 2026. Both countries move to the grey list of states that have made reform commitments, which carries lighter consequences than full listing. The change takes effect once the revised annexes appear in the Official Journal of the European Union.

Panama’s exit from the EU tax blacklist followed reforms to its foreign-source income exemption regime, which led the Council to drop the criterion on harmful preferential tax measures. The country now sits on the grey list with a commitment to undergo an in-depth review of how it exchanges tax information on request. Vietnam moved after the Global Forum on Transparency and Exchange of Information for Tax Purposes granted an in-depth review following a non-compliant rating, so its commitments on country-by-country reporting now appear in the grey list.

The EU tax blacklist, formally Annex I of the Council conclusions, now names eight jurisdictions. They are American Samoa, Anguilla, Guam, Palau, Russia, the Turks and Caicos Islands, the US Virgin Islands and Vanuatu. Anguilla and Vanuatu stay on it under the criterion on facilitating offshore structures, although Vanuatu’s separate entry on information exchange on request disappeared after a supplementary review rated it largely compliant. Belize left the grey list altogether after it earned a largely compliant rating in the Global Forum peer review.

The grey list, known as Annex II, now holds ten jurisdictions. They are the British Virgin Islands, Brunei Darussalam, Eswatini, Greenland, Jordan, Montenegro, Morocco, Panama, Türkiye and Viet Nam. Brunei received an extension to 22 December 2026 to deliver on its commitments. Türkiye stays under the automatic exchange criterion because it does not yet exchange information with Cyprus, while Montenegro awaits its in-depth review on information exchange on request.

Listing matters because member states can apply defensive measures at national level to blacklisted jurisdictions, and certain EU financing rules restrict dealings with them. A move to the grey list therefore reduces exposure for banks, investors and multinational groups that do business with Panama and Vietnam. Tax advisers will now check whether intra-group payment structures that triggered extra scrutiny under the EU tax blacklist still need the same safeguards.

The Council reviews the EU tax blacklist twice a year, and the next update is expected in February 2027. That review will test whether Brunei, Türkiye and the other grey-list states deliver on their pledges before their deadlines. Finance ministries and national revenue authorities will watch those reviews closely, because the Global Forum’s ratings now drive most of the movements on the list.

For tax advisers and multinational groups, the October decision shows that the EU tax blacklist responds to concrete legislative change and peer-review results rather than diplomacy alone. Panama and Vietnam must still deliver on their commitments, and any slip before the February 2027 review would put them at risk of returning to the list.