On 9 October 2026, the Council of the EU updated the EU list of non-cooperative jurisdictions for tax purposes. The main change is that Panama and Vietnam have been removed from Annex I and moved to Annex II (list of cooperative jurisdictions), where they will remain subject to ongoing monitoring.
Annex I now includes eight jurisdictions: American Samoa, Anguilla, Guam, Palau, Russia, the Turks and Caicos Islands, the US Virgin Islands and Vanuatu.
For Czech companies, the update may also have consequences under the CFC rules. Section 38fa (2) of the Czech Income Taxes Act applies a stricter regime where a controlled foreign company is resident in an Annex I jurisdiction at the end of its tax period. In such cases, income of the foreign company may be attributed to the Czech controlling company for Czech tax purposes. As the relevant test is applied at the end of the foreign company’s tax period, the removal of Panama and Vietnam from Annex I may already be relevant for tax periods ending after 9 October 2026, including, in particular, calendar-year periods ending on 31 December 2026.
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