A Profoundly Transformed International Tax Landscape

Attractive tax jurisdictions still exist in 2026, but the way they operate has changed significantly over the past fifteen years.

Driven by the work of the OECD, the G20, and the European Union, tax transparency has been considerably strengthened.

The automatic exchange of information, base erosion and profit shifting (BEPS) rules, increased reporting obligations, and the progressive introduction of a 15% global minimum tax for large multinational groups have profoundly reshaped international profit-location strategies.

Nevertheless, many companies continue to establish certain activities in jurisdictions offering a competitive tax environment, provided these operations correspond to genuine economic activity and comply with national and international regulations.

The French List of Non-Cooperative Tax Havens

France publishes an annual list of Non-Cooperative States and Territories (ETNC), as provided for under Article 238-0 A of the French General Tax Code.

This list does not target territories with low taxation, but rather jurisdictions that do not sufficiently comply with international tax transparency standards or that do not cooperate with French authorities.

The composition of this list changes regularly depending on the commitments made by the jurisdictions concerned. It must therefore be checked before any international transaction.

Furthermore, transactions carried out with States or territories on this list are subject to particularly stringent tax measures under French law (enhanced presumptions, increased withholding taxes, limitations on certain deductions, specific reporting obligations, etc.).

An Approach Now Based on Economic Substance

The era when it was enough to set up a “letterbox” company in a low-tax jurisdiction is now largely over.

Tax authorities today verify the existence of genuine economic substance: the presence of directors, employees, and premises, functions actually performed, and real decision-making taking place in the jurisdiction of establishment.

Anti-abuse measures, controlled foreign company (CFC) rules, reporting obligations, and automatic information exchange significantly limit purely artificial arrangements.

Jurisdictions That Remain Highly Attractive

Certain jurisdictions nonetheless continue to attract international investors thanks to a stable economic environment, a highly competitive tax system, and a secure legal framework.

Among the most frequently used financial centers are:

• Singapore, recognized for its political stability, its network of tax treaties, and its role as an Asian platform;
• Hong Kong, which despite recent institutional developments remains a major international financial center;
• the United Arab Emirates, particularly the free zones of Dubai and Abu Dhabi, which host numerous international companies;
• Switzerland, whose appeal now rests more on the quality of its economic and financial environment than on its banking secrecy, which has largely disappeared;
• Luxembourg, which retains a major position in the investment fund, finance, and international holding company sectors;
• Ireland, which remains attractive thanks to its economic environment, its technology ecosystem, and its corporate tax rate, now integrated within the new international rules.

Increasingly Regulated Jurisdictions

Conversely, certain jurisdictions historically regarded as tax havens have lost much of their appeal.

Panama, the British Virgin Islands, the Seychelles, and several Caribbean territories have strengthened their transparency requirements, beneficial ownership disclosure rules, and cooperation with foreign tax authorities.

These territories are still used for certain international activities, but regulatory requirements are now far more stringent than in the past.

Choosing an International Location

The choice of an international location can no longer be based solely on international tax optimization.

Companies now take into account a range of factors, including:

• political and legal stability;
• the network of tax treaties;
• the quality of infrastructure;
• access to international markets;
• economic substance requirements;
• operating costs;
• the legal security of investments.

Taxation is now just one element among others in an international strategy that must be economically justified and compliant with both national and international rules.

A Strategy to Be Built with Caution

In 2026, tax-attractive jurisdictions continue to offer opportunities for companies engaged in international activity. However, strategies based solely on seeking low taxation have become considerably riskier.

The success of an international project now depends on establishing genuine economic substance, meeting tax compliance requirements, and fitting into a broader international tax optimization strategy.