Panama and Viet Nam: EU agrees a tax list change

What changed

On October 9, 2026, the Council of the European Union agreed to remove Panama and Viet Nam from Annex I of its list of non-cooperative jurisdictions for tax purposes. Both move to Annex II, which records cooperation alongside outstanding commitments or reviews.

Both jurisdictions are awaiting an in-depth Global Forum review of their exchange of tax information on request. The move therefore does not mean that every review is complete. It changes the documented EU classification that may have informed an earlier assessment of a company or payment.

Who is affected

The immediate audience is founders, private clients, and their advisers with companies, investments, or payments involving Panama or Viet Nam and a relevant EU connection. The clearest reason to act is a transaction that was expressly held back because of Annex I status.

For a proposed structure, request an updated country assessment. For a transaction already in preparation, first establish whether this particular tax list caused the restriction. An objection based on a different requirement may remain even when the classification changes.

A case with no relevant connection to either jurisdiction has no direct action arising from this decision. The change also does not determine anyone’s residence permit or personal tax residence. Its subject is tax list classification and the consequences that the applicable rules attach to it.

What to check now

1. 01

   Identify the decision that was held back

   Founder, CFO, or family office

   Bring together the recipient, entity, amount, intended date, and recorded reason for the restriction. Include the earlier written advice or rejection. This makes it possible to test whether the new classification changes an actual decision in your file.

2. 02

   Confirm the rule and its timing

   Responsible tax adviser or lawyer

   Ask which national provision, list version, and application date govern that transaction. The conclusion should specify what changes, when it changes, and which conditions remain. A general announcement about removal from the list cannot answer those questions for an individual arrangement.

3. 03

   Confirm that the transaction can proceed

   Bank or responsible counterparty

   Present the updated assessment and establish which documents and acceptance conditions are still required. Use that response to schedule the next step. A favorable tax conclusion on its own does not show that the institution will process the proposed transaction.

Reassess whenBefore the next payment, distribution, or structural decision involving Panama or Viet Nam; revisit on verified Official Journal publication or relevant national implementation.

The wider context

No Borders Founder’s practical reading is a sequence: retrieve the original reason, check whether its legal basis still applies, then approach the party responsible for execution. That converts an encouraging announcement into a specific change that can be checked and documented.

Our deeper analyses of international bankability and tax residence selection explain the wider decision. This list change alone is not a reason to relocate or replace a structure. The relevant test remains what the arrangement must do and whether it can perform that function under the client’s actual circumstances.