Asset Protection · Banking Solutions

Blacklists and grey lists: how to avoid the tax haven traps

Low-tax jurisdictions are perfectly legal. But pick the wrong one and you may find your bank asking uncomfortable questions, your client’s payment stuck in compliance, or your home tax office suddenly very interested in you.

The culprit is usually a list. Here’s what the lists are, what they do and how to stay off the wrong side of them.

Blacklist vs grey list

Both lists flag jurisdictions that don’t meet international standards. The difference is urgency.

  • Blacklist. The jurisdiction is considered non-cooperative or high-risk. Other countries apply countermeasures, and banks often won’t touch it.
  • Grey list. The jurisdiction has committed to fix its shortcomings and is being monitored. No formal sanctions, but plenty of extra scrutiny – and the risk of moving to the blacklist if reforms stall.

We’ve lived through the grey-list experience with our own structures more than once. It’s not dramatic, just slow, expensive and annoying: extra questions for every payment, longer onboarding, partners who suddenly “need to review the relationship”.

The lists that matter

There isn’t one global blacklist. There are several, and they measure different things.

ListWhoWhat it measuresUpdated
EU list of non-cooperative jurisdictionsEU CouncilTax transparency, fair taxation, BEPS standardsTwice a year
EU “state of play” (grey list)EU CouncilJurisdictions with open commitmentsTwice a year
FATF “call for action” (black list)Financial Action Task ForceAnti-money-laundering and terrorist-financing controlsThree times a year
FATF “increased monitoring” (grey list)Financial Action Task ForceSame, for countries fixing gapsThree times a year
EU high-risk third countriesEuropean CommissionMoney-laundering risk, largely following FATFSeveral times a year

The EU tax list

The EU list of non-cooperative jurisdictions for tax purposes looks at tax transparency, fair tax competition and whether a country implements minimum international standards against profit shifting.

If a country is blacklisted, EU member states apply defensive measures. These can include denying tax deductions for payments to that country, higher withholding taxes, stricter CFC rules and extra reporting duties for advisors. In practice: paying a supplier in a listed country gets expensive and complicated.

The OECD’s role

The OECD doesn’t run a blacklist in the old sense anymore. Its Global Forum peer-reviews countries on exchange of information – on request and automatically under CRS – and rates them. Those ratings feed directly into the EU list and into how banks see a country.

The FATF lists

The Financial Action Task Force is the global anti-money-laundering watchdog. Its lists are not about tax rates at all. They’re about whether a country’s financial system is protected against money laundering and terrorist financing.

It still matters enormously for anyone doing business internationally, because banks build their risk models around these lists. Once a country is on the FATF grey list, even perfectly clean transactions get extra scrutiny. On the black list, many banks simply stop.

Lists also move both ways. The UAE, for example, was on the FATF grey list and left it in February 2024 after reforms. That’s why a single blog post – including this one – is no substitute for checking the current version.

What listing means for your business

Even if everything you do is legal, a listed jurisdiction can cost you.

  • Banking. Longer onboarding, more KYC and AML questions, higher fees – or a polite “no”. Payment providers are often even stricter.
  • Tax. Your home country may deny deductions, apply withholding taxes or tax the company’s profits directly under CFC rules.
  • Reputation. Clients, investors and partners run their own checks. “Registered in a blacklisted jurisdiction” is not a great first line in a due diligence report.
  • Compliance costs. More documentation, more audits, more advisors.

If you already have a structure in a grey-listed country, don’t panic. Keep your documentation spotless, be transparent with banks, and have a plan B in case the country slides onto the blacklist.

Safer low-tax jurisdictions

Low tax and good standing aren’t opposites. Plenty of jurisdictions offer both:

  • Estonia – 0% on retained profits, 22% on distributions, fully digital, EU member.
  • Malta – about 5% effective for foreign shareholders via the refund system, EU and Schengen.
  • Cyprus – 15% corporate tax since 2026, attractive non-dom regime, EU member.
  • Dubai (UAE) – 0% corporate tax up to AED 375,000 of profit and 9% above, 0% for qualifying free zone income, no personal income tax.
  • Liechtenstein – 12.5% flat, Swiss franc, strong reputation.

These countries expect real substance and full reporting in return. That’s a fair trade: slightly more paperwork, far fewer surprises. Compare them in our country comparison, or read how to legitimize your presence in a tax haven.

This article is general information, not tax or legal advice – list status and consequences depend on your situation and change over time.

Not sure which jurisdiction fits? Try the jurisdiction finder.

More nerdy insights?

Keep reading.

All insights

Nerdy Strategy Session

Still unsure? Get an expert opinion.

Read everything, still not sure which setup fits you? In 90 minutes we go through your situation with you and turn it into a written roadmap – what to set up where, in which order, and what it will cost.

  • 90-minute video call with a senior strategist
  • Written roadmap within 5 working days
  • 30 days of follow-up questions by e-mail
  • Fully credited if you set up with us within 6 months

€1,490 one-off, plus VAT where applicable

Book your session Know exactly what you need? Get a quote instead

Free quote · non-binding

Still not sure? Get in touch with us!

Already know what you want to set up? Tell us and we’ll send you one fixed quote from a vetted, licensed partner in the right jurisdiction. Not sure yet? Book a strategy session first – it’s credited if you go ahead.

  • Free and non-binding
  • Reply within two working days
  • One contract, one invoice
  • We never sell your data
1 / 3 · What do you want to do?
2 / 3 · A bit of context
3 / 3 · Where can we reach you?

Strategy sessionFind your country