[Recap] GBA Workshop: Vietnam on the EU Blacklist – Creating Clarity for Foreign Investment

On 31 March 2026, the German Business Association (GBA), in collaboration with Graf von Westphalen Vietnam (GvW), successfully hosted the workshop “Vietnam on the EU Blacklist – Creating Clarity for Foreign Investment in Vietnam” at Deutsches Haus Ho Chi Minh City.

The session brought 34 participants together including business leaders, legal experts, and investors to unpack the implications of Vietnam’s recent inclusion on the EU list of non-cooperative jurisdictions for tax purposes, as adopted by ECOFIN on 17 February 2026.

Led by Mr. Stefan Ewers, Partner, and Ms. Xuan Vo, Tax Advisor & Senior Associate at GvW, the workshop provided a structured and practical overview of how this development impacts EU–Vietnam business operations.

A key takeaway highlighted during the session is that Vietnam’s inclusion on the EU blacklist does not result in any immediate changes to domestic tax rates or structures. However, it signals upcoming regulatory reforms and increased compliance requirements over time.

Participants gained valuable insights into four key defensive tax measures increasingly applied by EU Member States:

  • Non-deductibility of costs for payments to Vietnamese entities, raising effective tax burdens
  • Enhanced Controlled Foreign Company (CFC) rules, requiring stronger proof of genuine economic activity
  • Increased withholding tax (WHT) rates on cross-border payments, potentially overriding double tax treaties
  • Limitations on participation exemption, affecting dividend flows and exit strategies

From a local perspective, while no direct tax increases are expected, businesses should anticipate enhanced transparency requirements, including stricter reporting on beneficial ownership, improved data exchange mechanisms, and broader information access by tax authorities.

Staying informed, maintaining robust compliance frameworks, and preparing for increased transparency requirements will be critical in navigating this evolving regulatory landscape.

GBA extends its sincere thanks to our speakers and all participants for contributing to an engaging and insightful discussion.

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