EU list of non-cooperative jurisdictions for tax purposes

Which countries are listed?

On 9 October 2026 the Council adopted the EU list of non-cooperative jurisdictions for tax purposes. There are 8 countries on the list.

The list becomes official upon publication in the Official Journal.

Listed: these countries do not cooperate with the EU or have not fully met their commitments

• Taxation: Council updates the EU list of non-cooperative jurisdictions for tax purposes (press release, 9 October 2026)

What is the EU list of non-cooperative jurisdictions?

Both within the EU and at the international level, the EU is working to promote and strengthen tax good governance mechanisms, fair taxation and global tax transparency in order to tackle tax fraud, evasion and avoidance.

Given the global nature of unfair tax competition, this also means addressing external challenges to EU countries' tax bases.

The aim of the EU list of non-cooperative jurisdictions, which is published as an annex to conclusions adopted by the Ecofin Council (annex I), is not to name and shame countries, but to encourage positive change in their tax legislation and practices through cooperation.

Jurisdictions that do not yet comply with all international tax standards but have committed to implementing reforms are included in a state of play document (annex II).

Countries which cooperate with the EU and have pending commitments

Once a jurisdiction meets all its commitments, its name is removed from the annex.

Countries which cooperate with the EU and have no pending commitments

When was the EU list established?

In November 2016, the Council mandated the Code of Conduct Group (business taxation), a special group established by the Council, to carry out the preparatory work to establish the list.

The Code of Conduct Group started with the screening of 92 jurisdictions, selected on the basis of:

• their economic ties with the EU
• their institutional stability
• the importance of the country's financial sector

The group’s screening and assessment report was submitted to the Council, and on the basis of the report, the first EU list was adopted on 5 December 2017. The list (annex I to the Council conclusions) included 17 non-EU countries or territories. These jurisdictions had not made sufficient commitments in response to the EU's concerns.

Accompanying the list was a state of play document (annex II) setting out which jurisdictions had responded with sufficient commitments. These jurisdictions were expected to take effective action by the end of 2018, or in some cases 2019, to avoid being listed in the future.

• Economic and Financial Affairs Council, 8 November 2016
• Council conclusions on criteria and process related to the EU list of non-cooperative jurisdictions, 8 November 2016
• Council conclusions of 5 December 2017 on the EU list of non-cooperative jurisdictions to tax purposes
• Code of Conduct Group on business taxation (background information)

How and when is the list updated?

Since it was first established in 2017, the list has been updated regularly and revised as a result of dynamic monitoring of the measures implemented by jurisdictions to comply with their commitments.

This is a continuous process which includes:

• updating criteria in line with international tax standards
• screening countries against these criteria
• engaging with countries that do not comply
• listing and de-listing countries as they undertake (or fail to undertake) reforms
• monitoring developments to ensure that jurisdictions do not backtrack on previous reforms

The monitoring process follows a set of procedural guidelines agreed on in February 2018.

Without changing the dynamic monitoring process, the Council decided in March 2019 to limit updates of the list to twice a year starting in 2020, to allow the EU member states sufficient time to amend domestic legislation where needed.

The latest revision took place in October 2026. The next revision is due in February 2027.

• Code of Conduct Group report to the Council, 6 February 2023
• Procedural guidelines for the monitoring process on the EU list of non-cooperative jurisdictions, 15 February 2018
• Outcome of proceedings on the harmful tax regimes (criterion 2.1)
• Outcome of proceedings on the harmful tax regimes (criterion 2.2)

What are the listing criteria?

To be considered cooperative for tax purposes, jurisdictions are screened on a number of criteria, established by the Council.

The criteria have been designed to evolve over time, so that they are aligned with international tax good governance standards, developed notably in forums of the Organisation for Economic Co-operation and Development (OECD) such as the Global Forum on transparency and exchange of information for tax purposes, the forum on harmful tax practices and the inclusive framework on base erosion and profit shifting.

The listing criteria relate to

• tax transparency
• fair taxation
• measures against base erosion and profit shifting (‘anti-BEPS measures’)

• Criteria for establishing the EU list of non-cooperative jurisdictions for tax purposes (background information)

Defensive measures and other relevant EU legislation and policies

For the EU list to be effective, it is important that EU member states put in place efficient defensive measures in non-tax and tax areas. Defensive measures help to protect their tax revenues and fight against tax fraud, evasion and abuse. 

When endorsing the EU list, the Council took the view that:

Effective and proportionate defensive measures, in both non-tax and tax areas, could be applied by the EU and member states vis-à-vis the non-cooperative jurisdictions, as long as they are part of such list. Council conclusions, 5 December 2017

• Council conclusions, 5 December 2017

Non-tax area defensive measures

Regarding non-tax areas, the Council invited EU institutions and member states to take the EU list into account in:

• foreign policy
• development cooperation
• economic relations with third countries

Furthermore, certain EU funding rules now explicitly refer to the list. Funds from several EU instruments cannot be channelled through entities in listed countries, including funds from the: 

• European fund for sustainable development (EFSD)
• European fund for strategic investments (EFSI)
• external lending mandate (ELM)
• general framework for securitisation

In its conclusions of 12 March 2019, the Council welcomed the fact that the list is being taken into account by the European Commission in the implementation of EU financing and investment operations.

• Regulation on the European fund for sustainable development and the guarantee fund
• Regulation on a general framework for securitisation
• Regulation on the European fund for strategic investments
• Regulation on the European fund for strategic investments and on the European investment advisory hub
• Decision on granting an EU guarantee to the European Investment Bank against losses under financing operations supporting investment projects outside the EU
• Regulation on the financial rules applicable to the EU general budget

Tax area defensive measures

EU member states have broad discretion over the type and scope of defensive measures they apply in the tax area. These largely depend on their national tax systems. Nevertheless, there is a certain degree of coordination.

National measures

EU countries agreed in December 2017 to apply at least one of the following administrative measures:

• reinforced monitoring of transactions
• increased risk audits for taxpayers who benefit from listed regimes
• increased risk audits for taxpayers who use tax schemes involving listed regimes

On 5 December 2019, the Council endorsed guidance on further coordination. Member states also committed, as of 1 January 2021, to use the EU list in the application of at least one of four specific legislative measures:

• non-deductibility of costs incurred in a listed jurisdiction
• controlled foreign company (CFC) rules, to limit artificial deferral of tax to offshore, low-taxed entities 
• withholding tax (WHT) measures, to tackle improper exemptions or refunds
• limitation of the participation exemption on shareholder dividends

Currently, all member states apply at least one of the four legislative defensive measures agreed in the 2019 guidance. Eighteen member states apply at least two of the four measures against jurisdictions mentioned in Annex I of the Council conclusions establishing the EU list of non-cooperative jurisdictions for tax purposes.

26 member states apply at least one administrative measure agreed upon in the 2019 guidance. Among them, twelve apply at least two measures. 

EU law

Recent EU legislation also explicitly refers to the list. For example, EU transparency rules for tax intermediaries were agreed on in 2018. These rules introduced new reporting requirements for tax schemes involving listed countries. They apply as of 1 July 2020.

• Directive on tax avoidance practices affecting the internal market
• Directive on mandatory automatic exchange of information in the field of taxation in relation to reportable cross-border arrangements
• Directive (EU) 2021/2101 of the European Parliament and of the Council of 24 November 2021 amending directive 2013/34/EU as regards disclosure of income tax information by certain undertakings and branches