Spain Updates List of Non-Cooperative Jurisdictions

Spain has just updated the rules defining which countries and territories are considered "non-cooperative jurisdictions" or tax havens. This news came with the publication of Orden HAC/649/2026, on June 21, which modifies the previous regulation, Orden HFP/115/2023, from February 9.

For those living in Spain or planning to move there, understanding this list is fundamental. The Spanish government uses this classification to combat tax fraud and ensure that residents do not use territories with opaque or detrimental tax regimes to hide income or assets.

What Has Changed With the New Regulation?

The new ministerial order (HAC/649/2026) comes into effect to strengthen transparency in the tax system. The central objective is to update the list of jurisdictions that do not cooperate with Spanish tax administration or have tax regimes considered "detrimental."

In practice, the regulation adjusts the criteria used to classify these territories. If you own investments, bank accounts, or receive income from countries listed on this list, the Spanish Tax Agency (Agencia Tributaria) will apply a much more rigorous scrutiny. This can mean higher taxation or additional reporting obligations in your Income Tax Return (IRPF) or Model 720, which is the declaration of foreign assets.

Why Does This Matter for Brazilians in Spain?

Many Brazilians maintain financial ties with their home country or make global investments through brokers in various jurisdictions. If any of the countries where you hold assets are included or remain on the list of non-cooperative jurisdictions, the oversight over these values is automatic and intense.

The list serves as a warning: Spain seeks to avoid "capital flight" and tax evasion. By maintaining assets in jurisdictions considered "non-cooperative," you place yourself at greater risk of audit or being subjected to punitive tax regimes under current legislation.

What Should You Do Now?

The first step is to check if any of your assets are located in countries listed on the updated Ministry of Finance list. We recommend following the information published directly on the Boletín Oficial del Estado (BOE).

If you have significant financial transactions abroad, the guidance is:

Check the official list on the BOE website.
Verify if the country where you hold assets has undergone any status changes with the new order HAC/649/2026.
If necessary, seek a specialized tax advisor (manager) in international taxation in Spain to ensure you are correctly declaring your income.

Tax transparency is one of the pillars of residence in Spain. Maintaining compliance with the requirements of the Hacienda avoids future headaches and heavy fines.