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· European Union · Offshore structuring

EU tax-list update: Panama and Viet Nam leave Annex I, BVI stays under monitoring

The Council's 9 October update moves Panama and Viet Nam to Annex II and removes Belize from monitoring. BVI remains in Annex II — a different status from the EU's non-cooperative list.

On 9 October 2026, EU finance ministers revised the EU list of non-cooperative jurisdictions for tax purposes. Panama and Viet Nam moved from Annex I to Annex II, while Belize left Annex II after fulfilling its commitments. Annex I now contains eight jurisdictions; Annex II contains ten jurisdictions with outstanding commitments or reviews. This briefing was published on 13 October; the Council decision dates from 9 October.

The distinction matters for European founders with offshore companies. Annex I is the list of jurisdictions considered non-cooperative for tax purposes. Annex II records jurisdictions cooperating with the EU but still subject to monitoring. The British Virgin Islands remains in Annex II. Neither category should be confused with FATF's separate anti-money-laundering lists, and a tax-list change is not a bank-account approval or a sanctions clearance.

For EU-resident owners, national defensive tax measures and disclosure requirements need to be assessed against the relevant country's rules and the arrangement itself. Moving off Annex I does not automatically remove every reporting obligation or establish that an offshore company's profits fall outside the owner's home-country tax system. Corporate residence, management and control, beneficial ownership and the commercial purpose of payments still matter.

Before changing an existing structure, ask your tax adviser which measures actually apply and when any change takes effect locally. Keep the ownership chart, contracts and business rationale consistent with your banking file. Xavion Capital can help coordinate company structuring and banking introductions; home-country tax conclusions require advice from a qualified adviser in the founder's country of residence.

Why it matters for banking

European founders using BVI or other offshore entities should explain the correct listing status, not describe every monitored jurisdiction as blacklisted. We help assess the structure and prepare the banking file, while each institution makes its own onboarding decision.

Sources: Council of the EU — conclusions of 9 October 2026 (PDF), KPMG EU Tax Centre — October 2026 list update. Summary for information only; not legal or investment advice.
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