On 9 October 2026, the Council of the European Union adopted the latest update to the EU list of non-cooperative tax jurisdictions (Annex I to Council Conclusions), effective for the 2027 fiscal year. The revised list adds three jurisdictions—Anguilla, Bahamas, and Turks and Caicos Islands—due to insufficient progress on harmful tax regime abolition and transparency standards. Meanwhile, Barbados and Jamaica were removed after implementing required reforms. The list now comprises 12 jurisdictions. For Greek taxpayers, the update triggers anti-abuse provisions under Article 36 of the Income Tax Code (Law 4172/2013): payments to entities in listed jurisdictions face restricted deductibility, heightened transfer pricing scrutiny, and mandatory disclosure under DAC6. AADE issued Circular E.2057/2026 detailing the domestic transposition timeline: Greek entities must apply the new list for transactions from 1 January 2027.
Key Takeaways
- List Changes: Additions: Anguilla, Bahamas, Turks and Caicos. Removals: Barbados, Jamaica. Current list: American Samoa, Anguilla, Bahamas, Fiji, Guam, Palau, Panama, Samoa, Trinidad and Tobago, Turks and Caicos, US Virgin Islands, Vanuatu.
- Domestic Impact: Interest, royalties, and service fees paid to listed jurisdictions lose deductibility unless the taxpayer proves genuine economic activity (substance test).
- Compliance Deadline: Greek companies must update their DAC6 reporting templates and transfer pricing documentation by 31 March 2027 to reflect the new list.
Disclaimer: This article is compiled and summarized by the AI based on publicly available information and is for general information purposes only. It does not constitute any form of formal tax advice, legal opinion, or basis for performance. Please consult a qualified professional tax advisor or legal counsel for tax advice.
Source: Read Official Announcement