Vietnam EU tax blacklist developments took a significant turn on October 9, 2026, when the Council of the European Union removed Vietnam from its list of non-cooperative jurisdictions for tax purposes. While the move is likely to improve investor confidence and reduce some tax-related concerns for cross-border transactions, Vietnam remains under monitoring through its placement in Annex II.
Key development
On 9 October 2026, the Council of the European Union (EU) decided to remove Vietnam from the EU list of non-cooperative jurisdictions for tax purposes, commonly referred to as the EU tax blacklist. Vietnam had been added to the list in February 2026 following an assessment by the OECD Global Forum that identified shortcomings in Vietnam’s framework for the exchange of tax information upon request.
The removal reflects Vietnam’s subsequent reform efforts. However, Vietnam has been moved to Annex II, which covers jurisdictions that have made commitments to implement international tax governance standards but remain subject to monitoring. Vietnam is awaiting an in-depth review by the OECD Global Forum of its exchange-of-information framework.
Review EU Tax Exposure
Assess whether existing withholding tax, reporting, or compliance requirements still apply to your business.What does this mean?
1. Improved international tax standing
Removal from Annex I represents progress in Vietnam’s cooperation with the EU on tax transparency and international tax governance. It may also support investor confidence and Vietnam’s efforts to attract foreign investment, particularly from European businesses.
2. Potential implications for cross-border transactions
The EU blacklist can influence the tax treatment of transactions involving listed jurisdictions, including certain defensive tax measures adopted by individual EU Member States. Vietnam’s removal from Annex I may therefore reduce concerns associated specifically with its former listing.
However, the actual impact will depend on the domestic tax rules of the relevant EU Member State, the nature of the transaction and the applicable effective dates. Businesses should not assume that all additional tax requirements or restrictions will automatically cease following the announcement.
3. Continued focus on tax transparency and BEPS compliance
Vietnam remains under monitoring in Annex II. The EU has also noted Vietnam’s commitment to address recommendations concerning parts B(1) and B(2) of the OECD’s Country-by-Country Reporting (CbCR) terms of reference, with a view to reflecting progress in the Action 13 peer review report in autumn 2027.
Strengthen Tax Compliance
Review your transfer pricing, CbCR, and reporting processes to stay ahead of regulatory changes.Recommended actions for businesses
Companies with Vietnam–EU cross-border operations should consider the following:
- Review EU tax exposure: Check whether the previous listing affected withholding tax, deductibility, reporting obligations or other defensive measures under the relevant EU Member State’s domestic legislation.
- Reassess transaction documentation: Review cross-border payments, related-party arrangements and supporting tax documentation where the former listing was identified as a compliance risk.
- Monitor further developments: Track the outcome of Vietnam’s OECD Global Forum review and future updates to the EU list.
- Maintain robust tax compliance: Continue to meet applicable transfer pricing, CbCR, tax reporting and information-disclosure requirements. Removal from the EU blacklist does not exempt businesses from these obligations.
Our perspective
Vietnam’s removal from the EU tax blacklist reflects the country’s continued efforts to strengthen its tax transparency framework, improve its regulatory environment and align with international tax governance standards. This development also demonstrates Vietnam’s commitment to constructive cooperation with the EU and the international community in addressing tax transparency concerns and promoting a fairer, more transparent global tax environment.
While this marks an important step forward, Vietnam remains subject to further monitoring and review. Businesses engaged in Vietnam–EU transactions should continue to monitor regulatory developments and assess the implications for their cross-border operations, taking into account the applicable tax rules in the relevant EU Member States.