Tax

On 9 October 2026, the EU Council published an update to its so-called “Blacklist” of jurisdictions that are not cooperative for tax purposes and “Grey List” of cooperative jurisdictions that have not yet fully met their commitments to comply with tax good governance standards. The Blacklist and Grey List were last revised on 17 February 2026.

In summary:

• Panama and Vietnam have been removed from the Blacklist, but have both been moved to the Grey List; and
• Belize has been removed from the Grey List.

The updated Blacklist and Grey List can also be found here.

Changes to the EU Blacklist

The Blacklist now comprises American Samoa, Anguilla, Guam, Palau, Russia, Turks and Caicos Islands, the US Virgin Islands, and Vanuatu.

Panama has been removed from the Blacklist following the reform of its foreign-source income exemption regime and the granting of a new review of its compliance with international standards on the exchange of tax information.  Vietnam has been removed from the Blacklist following a series of reforms to its compliance with those standards and has also been granted a new review. Both jurisdictions have been added to the Grey List pending the outcome of those reviews.

Changes to the EU Grey List

The Grey List now comprises the British Virgin Islands, Brunei, Eswatini, Greenland, Jordan, Montenegro, Morocco, Panama, Turkey, and Vietnam.

Belize has been removed from the Grey List after receiving a positive rating from the OECD Global Forum regarding its systems for exchanging tax information on request, having now fulfilled its commitments in that respect.

Key action for private fund sponsors

As we have noted in connection with previous updates to the EU lists, the Blacklist and Grey List may feature in contractual undertakings in certain side letters. Private fund sponsors should consider their compliance with any such provisions in light of the updates to the lists, as well as take into account the lists more generally when making and/or structuring investments.

The next update to the Blacklist and Grey List is expected in February 2027.