- British Virgin Islands, and
- Panama.
- Antigua and Barbuda
- Belize
- Russia, and
- Seychelles.
The full list includes: Anguilla, Antigua and Barbuda, Bahamas, Belize, Fiji, Guam, Turks and Caicos Islands, US Virgin Islands, Palau, Russia, Samoa, American Samoa, Seychelles, Trinidad and Tobago, Vanuatu.
As a reminder:
Once on the list of non-cooperative States and territories, the jurisdiction is subject to restrictive measures, depending on the reasons for inclusion on this list:
- Failure to exchange tax information (such as the Seychelles) present on the list because even if a convention has been signed, the terms or the implementation have not enabled the tax authorities to obtain the information required for the application of French tax legislation.),
- Facilitating the creation of offshore structures or arrangements whose purpose is to attract profits without any real economic activity; or
- Other criteria such as the absence of potentially harmful preferential tax measures, failure to implement anti-BEPS measures or lack of tax transparency.
The list had already been updated in February 2023 and December 2019.
To recap, here is the complete list of countries according to the reason for their presence on the list:
- Reason 1: No treaty on administrative assistance with at least 12 countries/territories including France or conditions or the implementation of the treaty did not allow the tax authorities to obtain the information necessary (CGI, art. 238-0 A, 2):
- Jurisdictions concerned: Seychelles.
- Restriction applies to: All tax break/incentive or favourable regime (participation exemption, withholding tax relief etc.)
- Reason 2: Facilitation of the creation of offshore structures or arrangements aiming at shifting profits without real economic activity (CGI, art. 238-0 A, 2 bis-1°):
- Jurisdictions concerned: Anguilla, Bahamas, Turks and Caicos Islands, Vanuatu
- Restriction applies to: All tax break/incentive or favourable regime (participation exemption, withholding tax relief etc.)
- Reason 3: Other criteria such as potentially harmful preferential tax measures, failure to implement anti-BEPS measures or lack of tax transparency (CGI, art. 238-0 A, 2 bis-2°):
- Jurisdictions concerned: Antigua and Barbuda, Belize, Fiji, Guam, United States Virgin Islands, Palau, Panama, Russia, Samoa, American Samoa, Seychelles, Trinidad and Tobago
- Restriction applies to: Restrictions apply only in case of cross reference to the blacklist
For more information, please contact office@rosemont-mc.com