Update of the fiscal paradises list

Ministerial Order No. 292/2025/1, of 5 September, updated the list of countries, territories, or regions with clearly more favourable tax regimes, published by Ministerial Order No. 150/2004, of 13 February, and updated by Ministerial Order No. 309-A/2020, of 31 December.

This list is approved by ministerial order issued by the member of the Government responsible for finance, after prior consultation with the Tax and Customs Authority, and taking into account the criteria set out in Article 63-D(2) of the General Tax Law.

In order to ensure that the list of countries, territories, or regions with clearly more favourable tax regimes remains up to date, the jurisdictions included therein may request the member of the Government responsible for finance to review their classification.

The Governments of the Hong Kong Special Administrative Region, the Principality of Liechtenstein and the Eastern Republic of Uruguay submitted formal requests for a review of their classification in the list, which have been given a positive opinion by the Tax and Customs Authority.

These territories are likewise not included in the EU list of non-cooperative jurisdictions for tax purposes, last updated on 18 February 2025.

Accordingly, numbers (31) Hong Kong, (40) Liechtenstein, and (79) Uruguay have been removed from the list of countries, territories, or regions with clearly more favourable tax regimes, contained in Ministerial Order No. 150/2004 of 13 February, in its current wording.

This update shall take effect from 1 January 2026.