Panama, Vietnam exit EU list; DAC6 hallmark narrows

Panama and Vietnam have been removed from the EU list of non-cooperative jurisdictions, narrowing the DAC 6 hallmark for cross-border payments. In the EU list update of 16 October 2026Skatteverket both countries were deletedSkatteverket, and Skatteverket's legal guidance Gränsöverskridande betalningar m.m. records the change in a 19 October 2026 entrySkatteverket: Panama is now listed as covered up to and including 15 October 2026Skatteverket, and Vietnam as covered from 6 March 2026 up to and including 15 October 2026Skatteverket.

The operative consequence sits in 19 § 2 b RAL. A cross-border arrangement is reportable under that hallmark where a deductible payment goes to a recipient resident in a country on the EU or OECD lists of non-cooperative jurisdictions.Skatteverket With Panama and Vietnam off the EU list, deductible payments to recipients there no longer trigger reporting under this hallmark. No OECD list softens or hardens this: Skatteverket notes it has found no OECD-assessed list of non-cooperative countries, so the EU list carries the assessment.

Timing follows the EU, not the guidance. Whether an arrangement is reportable follows the EU's list updates, not the date of Skatteverket's guidance update.Skatteverket The assessment point works as follows: an arrangement provided while the recipient's country is listed is reportable if the country is still listed when the reporting duty arises or the report is filedSkatteverket, while a country removed before that point takes the arrangement outside 19 § 2 bSkatteverket. Conversely, an already-implemented arrangement does not become reportable merely because the recipient's country is added to a list, absent other changes to the arrangementSkatteverket. For 19 § 2 b no main-benefit test applies: unlike some hallmarks, reportability does not require the tax advantage to be a main benefit of the arrangement.

The updated 2026 list comprises Amerikanska Samoa, Anguilla, Guam, Palau, Ryssland, Amerikanska Jungfruöarna and Vanuatu for the full year, plus date-bounded entries: Fiji, Samoa and Trinidad och Tobago up to 5 March 2026Skatteverket, Turks- och Caicosöarna from 6 March 2026Skatteverket, Panama up to 15 October 2026, and Vietnam from 6 March to 15 October 2026. The list is revised twice a year, so advisers check the current version rather than relying on a filed copy.

Legal basis: Lag (2020:434) om rapporteringspliktiga arrangemang 19 § 2 b on reportable deductible payments to recipients in listed jurisdictionsSkatteverket; the EU list of non-cooperative jurisdictions as updated on 16 October 2026.