This revision follows the latest update of the EU blacklist adopted by the ECOFIN Council on 17 February 2026, although France continues to apply its own domestic criteria in addition to the European framework.
Vietnam has been added to the French list, while Fiji, Samoa and Trinidad and Tobago have been removed.
The French NCCT list now includes the following jurisdictions and territories:
- American Samoa
- Anguilla
- Antigua and Barbuda
- Guam
- Palau
- Panama
- Russian Federation
- Turks and Caicos Islands
- US Virgin Islands
- Vanuatu
- Vietnam
It should be noted that Antigua and Barbuda remain on the French list despite having been removed from the European Union blacklist, as France is also applying its own domestic criteria.
For reminder purposes, and in accordance with Article 238-0 A of the French Tax Code, the French NCCT list includes States and territories which:
- do not comply with French standards regarding the exchange of tax information; or
- appear on the European list of non-cooperative jurisdictions for tax purposes according to the criteria retained by the Council of the European Union.
This notably concerns jurisdictions considered by the European Union as:
- facilitating the implementation of offshore structures allowing the attraction of profits without sufficient economic substance; or
- not complying with international standards relating to tax transparency, fair taxation and the implementation of measures aimed at combating base erosion and profit shifting (“anti-BEPS”).
The inclusion of a jurisdiction on the French NCCT list may trigger the application of various defensive tax measures, depending on the reasons that led to such listing.
In practice, this may notably impact:
- withholding taxes;
- the deductibility of certain payments;
- certain reporting obligations;
- transfer pricing analyses; and
- the application of certain anti-abuse provisions.
International groups, family offices, trustees and structures holding assets or operations connected to listed jurisdictions may therefore wish to review their existing arrangements in order to assess the potential consequences of this update.
The previous update of the French list of Non-Cooperative States and Territories dated back to May 2025.
For more information, please contact office@rosemont-mc.com
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