In addition to Russia, the British Virgin Islands and Costa Rica will also be newly included, and the Marshall Islands will be listed again (see press release dated Feb. 14, 2023).
For jurisdictions named in the EU blacklist, the national tax haven defense law stipulates, among others, stricter rules for the taxation of additional income, an extension of withholding tax collection to additional income, restrictions on the application of DTA regulations and increased obligations to cooperate. The newly listed countries will be affected from 2024 onwards, provided that the Tax Haven Defense Regulation is adapted accordingly to the new EU blacklist by the end of the year. In subsequent years, further tightening of dividend taxation and business expense deductions would be added.
Note: The EU blacklist also has an impact on the reporting requirements for cross-border tax arrangements (DAC6).
