In mid-February, the European Council updated the EU list of non-cooperative jurisdictions for tax purposes (“the EU blacklist”). In addition to the British Virgin Islands, Costa Rica, and the Marshall Islands, Russia was added to the list.
In the context of Czech tax legislation, this step may have an impact on the application of the legal fiction of the CFC rules for taxation of controlled foreign companies (e.g. Russian subsidiaries held by Czech parent companies).
Please note that different countries refer to or use the list in the context of e.g. penalty rates, regimes, etc., thus it is a good idea to verify the potential impact of updating the list abroad.
The next revision of the list will take place in October 2023, nevertheless, it is advisable to keep the list in mind, especially with regard to the taxable period of the companies and possible participation in the countries concerned (especially in Russia).
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