Ordinance No. 292/2025/1, of 5 September, updates the list of countries, territories or regions with clearly more favourable tax regimes, initially approved by Ordinance No. 150/2004, of 13 February.
Ordinance No. 292/2025/1, of 5 September
Following formal requests submitted by the jurisdictions concerned and after a favourable opinion from the Tax and Customs Authority, the following territories were excluded from the tax blacklist:
- Hong Kong
- Liechtenstein
- Uruguay
The decision also aligns with the European Union's list of non-cooperative jurisdictions for tax purposes, from which these jurisdictions have been removed.
Main implications for taxpayers and entities
The tax increase associated with various transactions involving these jurisdictions ceases. One example is the end of the application of the increased withholding tax rate of 35%, in contrast to the lower rates applicable in normal situations (e.g. 25% or lower rates provided for in the respective double taxation agreements).
Economic transactions with Hong Kong, Liechtenstein and Uruguay will now be governed by the general regime, eliminating the additional burdens that have applied until now.
Entry into force
The Ordinance enters into force on the day following its publication, but takes effect from 1 January 2026, and taxpayers and entities must adjust the tax treatment of their transactions with these jurisdictions by that date.
