Mise à jour de la liste française des États et territoires non coopératifs (ETNC)

The Order of 15 April 2026, published in the Official Journal of 26 April 2026, updated the French list of non-cooperative States and territories (NCSTs) for tax purposes.

It incorporates the changes made by the Council of the EU to its “black” list of non-cooperative jurisdictions on 17 February 2026.

Vietnam has now been added to this list because it does not sufficiently comply with the standard on the exchange of tax information on request. As such, only some of the French deterrent measures will apply to it.

The Turks and Caicos Islands were already on the French list under domestic law criteria. They are now also listed because they have been added to the European blacklist (offshore criterion). In practice, this will have no consequences for these Islands, as they were already subject to all the deterrent measures.

By contrast, Fiji, Samoa and Trinidad and Tobago have been removed from the list.

As a result of their inclusion on the French NCST list, transactions carried out with these NCSTs are subject to heavier taxation.

The various restrictive measures applicable depend on the grounds or criteria for inclusion on the NCST list.

In practice, the new NCST list is therefore as follows:

• Antigua and Barbuda
• Vanuatu
• Anguilla
• Turks and Caicos Islands
• Guam
• US Virgin Islands
• Palau
• Panama
• Russia
• American Samoa
• Vietnam

In principle, these restrictive measures will apply to the States added to this list, i.e. Vietnam, from the first day of the third month following publication of the Order, i.e. from 1 July 2026.

By contrast, these measures cease to apply to the States removed from the list as from the date of publication of the Order, i.e. 26 April 2026.