October 20th, 2023

The European Council, on October 17th, 2023, added Belize, Seychelles, Belize, and Antigua & Barbuda to the EU list of non-cooperative countries, and removed British Virgin Islands (BVI), the Marshall Islands and Costa Rica from the same list.

Costa Rica was removed from the list after amending its exemption on foreign source income, Marshall Islands was removed after introducing substance standards, and the BVI were removed after it amended its exchange of information (EOI) regime.

The inclusion of a country on the EU list of non-cooperative countries effectively means that payments made from EU countries to the included jurisdiction are subject to withholding tax at source.

The implementation against non-cooperative countries by Cyprus which by law does not impose withholding tax on dividends, interest, or royalties unless its intellectual property registered in Cyprus, will mean the application of withholding tax of 17% on company payments of dividends, of 30% on interest payments and of 10% on royalties’ payments, excluding payments by individuals in all cases.

As of October 17th, 2023, the EU list of non-cooperative countries includes American Samoa, Antigua and Barbuda, Anguilla, Bahamas, Belize, Fiji, Guam, Palau, Panama, Russia, Samoa, Seychelles, Trinidad and Tobago, Turks and Caicos Islands, US Virgin