Spain has revised its list of non-cooperative jurisdictions and harmful tax regimes, removing six jurisdictions or regimes while adding Russia's international holding company regime, with different implementation dates applying to the changes.
Spain has updated its list of non-cooperative jurisdictions and harmful tax regimes following the publication of Order HAC/649/2026 in the Official Gazette on 27 June 2026.
The order amends the list established under Order HFP/115/2023 to reflect international standards developed by the European Union and the OECD as part of efforts to strengthen tax transparency and combat tax fraud.
Under the revised list, Barbados, Dominica, Gibraltar, Seychelles and Trinidad and Tobago have been removed from the list of non-cooperative jurisdictions. Samoa has also been removed, but only in relation to its harmful tax regime for offshore business.
The order also adds the Russian Federation’s international holding company regime to the list of harmful tax regimes considered non-cooperative.
For the jurisdictions and regimes removed from the list, the order entered into force on 28 June 2026, the day after its publication. The changes apply from that date to taxes without a tax period and to taxes accrued from the date of entry into force. For taxes with a tax period, the amendments apply to tax periods beginning on or after 28 June 2026.
The inclusion of the Russian international holding company regime will take effect six months after publication, on 28 December 2026. The same application rules will apply from that date, covering taxes without a tax period and taxes accrued from the date of entry into force, as well as tax periods beginning on or after 28 December 2026.
The order also includes a transitional provision under which the previous list established by Order HFP/115/2023 will continue to apply to taxes whose tax period was already in progress when the new order entered into force until the end of that tax period.
The Ministry of Finance stated that the revision is intended to keep Spain’s framework for identifying non-cooperative jurisdictions aligned with international developments on tax transparency and fair taxation.
