Just two weeks ago, the Ministry of Finance published in the official gazette an update that has gone fairly unnoticed in the general media — but that is true implications for entrepreneurs, freelancers, and people with structures or economic ties in certain territories.
On June 27, 2026 entered into force the Order HAC/649/2026, which modifies the Spanish list of non-cooperative jurisdictions — what used to be called just a list of tax havens. The change was most striking: Gibraltar ceases to be a tax haven for Spain for the first time in 35 years.
But there's more. In total, leaving six territories and enters a new one. And that again is Russia.
What exactly is the list of non-cooperative jurisdictions?
The list of non-cooperative jurisdictions is the instrument that Spain used to identify territories that do not meet the international standards of tax transparency. Operate to a country or territory that is in that list has tax consequences concrete: greater burden documentary, highest retention rates, the presumption that certain operations can be elusive and obligations to provide information additional.
In 2023 replaced the classical concept of tax haven for the jurisdiction not cooperative, aligning the Spanish legislation with the standards of the EU and the OECD. Since then, the list is reviewed at regular intervals — and this update is the most significant of the last few years.
The six territories that come out — and why it matters
With effect from June 28, 2026, are no longer in the list in the black Spanish or non-cooperative jurisdictions: Gibraltar, Barbados, Dominica, Samoa (as compared to his regime offshore business), Seychelles, and Trinidad and Tobago.
The output of Gibraltar is the most relevant from the practical point of view. The Rock has signed a bilateral agreement of cooperation tax with Spain in 2019, whose operation has been verified successfully. In addition, Gibraltar is part of the Global Forum on Transparency and Exchange of Information for Tax Purposes, it participates in the framework of BEPS OECD and has ratified the Pillar II — the settlement of tax global minimum of 15%.
The decision is supported by technical criteria, not by gestures diplomats. Gibraltar no longer maintains a regime of low or no taxation in accordance with the parameters of the OECD — and that is what matters for the purposes of the list.
For the rest of the territories that come out, the reasoning is similar: they have advanced enough in terms of transparency and exchange of information to meet the international standards required.
What changes in practice, if you work with these territories?
Automatic output from the 28th of June has immediate effects. If you have operations, accounts, or economic ties with Gibraltar, Barbados, Dominica, Samoa, Seychelles, or Trinidad and Tobago, you no longer have to treat them as non-cooperative jurisdictions.
This translates into several concrete advantages: it simplifies the statement of related party transactions by the Model 232, it is not necessary to identify these transactions as carried out with a tax haven, and in some cases taxpayers may be exempt from present on the Model 720 for property in such territories, provided that they do not have other assets in countries that follow in the list.
For self-employed and businesses with suppliers or customers in these territories, the paperwork will be significantly reduced and removed the presumption that such operations have motivation to be elusive.
Yes, there is that to avoid a common mistake: to continue to make such operations as if the country is still in the black list can lead to inconsistencies in the statements and wake up checks of the Treasury. The change is that it should also be referred to the internal systems of billing and accounting records.
The novelty that goes more unnoticed: Russia joins the list of non-cooperative jurisdictions
At the other end of this update, the Federation of Russia is incorporated for the first time to the Spanish list of non-cooperative jurisdictions — although only partially. Do not enter Russia as to jurisdiction in its entirety, but specifically its tax regime called international holding companies.
The European Union already had included in its own black list in February 2023. Spain is now the same line. The incorporation of the Russian regime will not take effect until six months after publication in the official gazette, i.e., approximately from December 2026.
The direct economic impact is reduced sanctions as a result of the war in Ukraine had already been restricted to a great extent the economic flows between Spain and Russia. But it adds an additional layer of control on any structure that still maintains links with Russian entities.
How is the list right now?
After this update, the Spanish list of non-cooperative jurisdictions is integrated by: Anguilla, Barein, Bermuda, Guam, Isle of Man, Cayman Islands, Falkland Islands, northern Mariana Islands, Solomon Islands, Turks and Caicos Islands, British Virgin Islands, U.s. Virgin Islands, Jersey, Palau, Russia, Samoa, and Vanuatu.
An important fact: Dubai and the United Arab Emirates are not on this list — have a double taxation convention with Spain and meet the international standards. The same thing happens with Georgia, Portugal or any other usual fate of the clients IURIT.
Do you have international structures or connections with any of these territories?
If you have a company, assets or business relationships with the territories which they appear or disappear from this list, it is advisable to check if there's something that you upgrade your obligations to provide information, or your tax planning.
In IURIT we work with businesses and individuals that operate at the international level and you need to have your situation correctly adapted to the regulatory changes. If you have doubts on how you are affected by this update, please contact us.
👉 Contact us in info@iuritcorp.com and what we see together without commitment.
You can also check our services Advice, International Tax and Business Structures International.
🔗 External link suggested: Official note of the AEAT about the update: headquarters.agenciatributaria.gob.is
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