Tax havens list 2026: Gibraltar exits, Russia enters and what changes for your company

Key data

If your company has operations, investments or subsidiaries in Gibraltar, Barbados, Dominica, Seychelles, Trinidad and Tobago or in the offshore regime of Samoa, the restrictive tax regime that applied to them disappears from 28 June 2026. At the same time, companies with links to Russian entities under the international holding companies regime must prepare for the new obligations that come into force in December 2026. The regulatory reference is Order HAC/649/2026, published in the BOE on 27 June 2026.

What does this regulation establish?

Order HAC/649/2026 modifies the Spanish list of non-cooperative jurisdictions (the current technical name for what was previously called the "tax haven list"). This list determines which territories and tax regimes receive more restrictive treatment under Spanish regulations: higher withholdings, limitations on deductions and enhanced reporting obligations.

The specific changes are as follows:

Territories and regimes that EXIT the list

Territories and regimes that ENTER the list

The regulation includes a transitional provision that protects tax periods in progress under the previous regulations, preventing companies from suffering retroactive effects from the changes.

Economic and operational impact

The impact varies depending on the territory and the direction of change:

For operations with Gibraltar (and the other 5 territories that exit): transactions are no longer subject to the restrictive tax haven regime. In practice, this means:

• Elimination of additional withholdings applicable to payments to non-cooperative jurisdictions.
• Removal of deduction limitations linked to operations with these territories.
• Reduction of enhanced reporting obligations in tax returns.

For operations with Russian entities under the international holding companies regime: from December 2026, these operations will be subject to the restrictive regime. This implies:

• New reporting obligations for transactions with these entities.
• Possible additional withholdings on payments made to these structures.
• Limitations on the deductibility of expenses linked to these operations.

The six-month deferred entry into force for Russia provides an adaptation margin until December 2026, but this deadline is limited for companies with complex structures.

Who does it affect?

• Spanish companies with subsidiaries or holdings in Gibraltar: benefit from the exit from the list; must review their returns and withholdings.
• Companies with operations in Barbados, Dominica, Seychelles, Trinidad and Tobago or with the Samoa offshore regime: same liberalizing effect as Gibraltar.
• Companies with links to Russian entities under the international holding companies regime: must prepare for new restrictions before December 2026.
• CFOs and financial directors managing international structures with presence in any of these territories.
• Tax advisors and consultants advising clients with investments or subsidiaries in the affected territories.
• Individuals with investments or accounts in Gibraltar or other territories exiting the list.

Practical example

Case 1 — Company with subsidiary in Gibraltar: A Spanish company with a subsidiary in Gibraltar had been applying additional withholdings and complying with enhanced reporting obligations in its tax returns because it was a non-cooperative jurisdiction. From 28 June 2026, those restrictive obligations disappear. The company must review its next settlements to avoid applying withholdings that no longer apply, and can simplify its international tax reporting.

Case 2 — Company with holding structure in Russia: A Spanish company that channels investments through a Russian entity under the international holding companies regime has until December 2026 to adapt its structure. From that date, payments to that entity could be subject to additional withholdings and linked expenses could lose deductibility. With six months of margin, it is advisable to start the analysis with your tax advisor now.

What should companies do now?

1. Identify if you operate in any of the affected territories: check if your company has subsidiaries, holdings, accounts or regular transactions with Gibraltar, Barbados, Dominica, Seychelles, Trinidad and Tobago, the Samoa offshore regime or Russian entities with holding company regime.
2. If you have operations with territories exiting the list: review the withholdings applied to payments and the reporting obligations declared. From 28 June 2026, the restrictive regime no longer applies. Coordinate with your tax advisor to adjust the next settlements.
3. If you have operations with Russian entities under the holding regime: start the impact analysis now. You have until December 2026, but structuring an appropriate response takes time. Consider whether the current structure remains efficient or whether it should be reorganized before the restrictions come into force.
4. Review the transitional provision: confirm with your advisor that tax periods in progress are protected under the previous regulations, as established by the transitional provision of Order HAC/649/2026.
5. Update internal tax compliance procedures: ensure that management and reporting systems reflect the new list of non-cooperative jurisdictions from the date of entry into force.

Official source

Consult full regulation in official source

Disclaimer: This article is for informational purposes only and does not constitute legal advice. For specific decisions, consult a qualified professional. Source: https://www.boe.es/diario_boe/txt.php?id=BOE-A-2026-13946