France has revised its list of non-cooperative states and territories under Article 238-0 A of the General Tax Code, adding Vietnam and removing Fiji, Samoa and Trinidad and Tobago, with the updated decree taking effect from 27 April 2026.
France has updated its list of non-cooperative states and territories for tax purposes through the Decree of 15 April 2026, published in the Official Gazette on 26 April 2026. The measure is issued under Article 238-0 A of the General Tax Code (CGI) and is part of France’s framework for identifying jurisdictions that do not meet international tax transparency standards.
The updated list now includes 11 states and territories: American Samoa, Anguilla, Antigua and Barbuda, Guam, Palau, Panama, Russia, Turks and Caicos Islands, US, Virgin Islands, Vanuatu, and Vietnam.
Compared with the previous 2025 list, there are several changes. Vietnam has been newly added, while Fiji, Samoa, and Trinidad and Tobago have been removed. The Turks and Caicos Islands remain listed and are now also covered under an additional legal criterion within Article 238-0 A of the CGI. Other jurisdictions such as Russia and Panama continue to appear under existing classifications.
Each jurisdiction is placed under specific legal bases defined in Article 238-0 A of the CGI. For example, Antigua and Barbuda is listed under paragraph b of 2, while Anguilla and the Turks and Caicos Islands fall under paragraph b of 2 and 1° of 2 bis. Several others, including Vietnam, Russia, Panama, Guam, US Virgin Islands, Palau, and American Samoa, are classified under 2° of 2 bis.
The decree was signed by Roland Lescure, Minister of Economy, Finance and Industrial, Energy and Digital Sovereignty, and David Amiel, Minister of Action and Public Accounts. It also reflects an opinion issued by the Minister of Europe and Foreign Affairs on 18 February 2026. The changes took effect on 27 April 2026, the day after publication.
