Summary

  • Panama and Viet Nam moved from Annex I to Annex II and await new Global Forum reviews; Belize alone left Annex II after a positive EOIR rating.
  • The Council recorded three different evidence states, not one verdict or a uniform change in legal consequences.

The Council’s 9 October release used “removed” for Panama and Viet Nam, but its conclusions give the precise move: both shifted from Annex I to Annex II and remain under follow-up. Belize took a different route, leaving Annex II after a positive Global Forum assessment of exchange of information on request (EOIR).

Panama reformed a harmful exemption for foreign-source income and was granted a new in-depth review. Viet Nam had entered Annex I in February 2026 after an earlier review found its EOIR framework below standard; following reforms it too was granted a new review. Both now await that review. Montenegro is in the same waiting group. A review being granted is not a favorable finding in advance: the Global Forum still has to assess law and practice. Its July technical assistance to Viet Nam discussed beneficial-ownership records, access to information and request handling, but did not announce a completed reassessment.

Belize’s evidence is further along. The Council says it fulfilled its commitment; the OECD’s 2026 review rates it “Largely Compliant” overall. That rating concerns EOIR, not every part of the tax system. Annex II tracks reform commitments still in progress; Annex I now contains eight jurisdictions. The Global Forum supplies peer-review evidence, while the Council assigns EU annex status under broader criteria. The Council says conclusions become official upon Official Journal publication. EU and member-state measures can refer to the list, but national tax tools differ.

The update therefore does not switch off one uniform penalty for all firms.

Sources

  1. Council press release, 9 October 2026
  2. Council conclusions ST 13854/26
  3. Council policy: the EU list
  4. Council timeline
  5. Council update on Viet Nam, 17 February 2026
  6. Global Forum, Viet Nam peer review (2025)
  7. Global Forum technical assistance to Viet Nam (July 2026)
  8. Global Forum, Belize in-depth review (2026)
  9. Global Forum overview of EOIR reviews
  10. Council procedural guidelines