Updated french list of non-cooperative states and territories


The list of non-cooperative States and territories (NCSTs) defined in Article 238-0 A of the French General Tax Code was updated by decree of 16 February 2024, published in the Official Journal of 17 February 2024.

The new French list of NCSTs for 2024 includes 16 States and territories: Anguilla, Seychelles, Bahamas, Turks and Caicos Islands, Vanuatu, Antigua and Barbuda, Belize, Fiji, Guam, the US Virgin Islands, Palau, Panama, Russia, Samoa, American Samoa and Trinidad and Tobago. 

The restrictive tax measures applicable to these States and territories depend on the reasons or criteria for classifying them in the list of NCSTs.

The 75% withholding tax on French-source income (dividends, interest) paid in an NCST and the 75% withholding tax on gains from employee shareholding schemes realised by persons resident in an NCST only apply to States and territories whose inclusion on the list is justified either by the fact that they do not allow the exchange of tax information, or by the fact that they facilitate the creation of extra-territorial structures or mechanisms to attract profits that do not reflect real economic activity (the 'reduced' list of NCSTs).

British Virgin Islands and Panama have been removed from the 'reduced' list of NCSTs with effect from 17 February 2024.