Updated french list of non-cooperative states and territories

The new French list of NCSTs for 2026 includes 11 States and territories: Anguilla, Antigua and Barbuda, Turks and Caicos Islands, Vanuatu, Guam, the US Virgin Islands, Palau, Panama, Russia, Samoa, American Samoa and Vietnam.

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).

The “restricted” NCST list for 2026 remains unchanged compared with the restricted list for 2025.

These changes entered into force on the day following publication of the order, i.e. 27 April 2026.