Vietnam has been added to the EU list of non-cooperative jurisdictions for tax purposes (the “EU blacklist”), following the Council’s update of 17 February 2026.

For EU companies buying goods and services from Vietnam, this is less about an immediate disruption to trade and more about heightened tax governance scrutiny, documentation expectations, and (sometimes) smoother-or-not payment execution depending on your Member State and your bank.

What the EU decision does (and does not) do:

The EU blacklist is a tax-governance instrument: it does not, by itself, prohibit EU businesses from importing goods from Vietnam or procuring Vietnamese services.
At the same time, the EU can deepen cooperation with Vietnam on the political and
economic track while still applying tax-governance pressure through listing mechanisms, so businesses should be prepared for a “partnership plus scrutiny” environment rather than expecting the two to be perfectly aligned.
In January 2026, the EU and Vietnam upgraded their relations to a Comprehensive Strategic Partnership, framed as a platform to strengthen cooperation across areas such as trade and investment, climate/energy, sustainable development and digital transformation.

How different payment types are affected in practice

Goods (imports) are often the most straightforward in substance terms because there is usually a clear chain of documents (purchase order, shipping documents, customs import paperwork, delivery notes, inspection/acceptance, and matching invoices).
The “risk uplift” for goods is typically not about whether the purchase is real, but whether the overall supply chain and pricing remain coherent under scrutiny (for example, whether margins and intercompany arrangements around the import flow make commercial sense and are consistently documented).

Services (outsourcing, consulting, IT development, marketing, support) tend to attract more questions because “what was delivered” can be harder to evidence than a shipped product. If your EU entity pays a Vietnamese provider for services, assume you may need a well-organised evidence pack: a clear scope of work, time records or milestones, deliverables (reports, code repositories, tickets), acceptance sign-offs, and a pricing rationale that matches the level of skill and effort.

Royalties and IP-related payments (software licences, trademarks, know-how, technology access) can be even more sensitive because they combine valuation complexity with cross-border tax characterisation questions.

In this category, expect pressure-testing of (i) who truly owns and controls the IP, (ii) the contract chain and sublicensing rights, (iii) how the royalty rate was set (benchmarking or comparable arrangements), and (iv) whether the payment is genuinely for IP rather than a disguised service fee.

Intragroup charges (management fees, shared services, cost recharges) are commonly the first area where tax authorities and counterparties ask for “benefit” evidence and allocation logic.

Where Vietnam sits inside a group value chain, be ready to show why a charge exists, how it was calculated, and how the recipient benefitted—plus consistent intercompany agreements and transfer pricing support.

Financing and treasury flows (interest, guarantees, cash pooling, factoring, trade finance) can trigger the most intensive technical review because they involve both tax outcomes and financial-crime/compliance sensitivities.

Even where the structure is legitimate, these flows can be more likely to be escalated internally for enhanced review and may require more supporting documentation before execution.

How European banks may respond (and what that looks like)

Banks in the EU operate under a risk-based approach to financial crime and compliance, and they may apply “de-risking” decisions—meaning they can choose to restrict or exit relationships or transaction types they view as exceeding their risk appetite or being operationally too costly to monitor.

Supervisory discussion acknowledges that de-risking exists and focuses on ensuring it is handled in a way that is proportionate and based on risk assessment rather than indiscriminate blanket exclusions.

For an EU company initiating a bank transfer to a Vietnamese counterparty, discretionary measures by the EU bank can include the following in practice (even if the payment is lawful and commercially routine).

The bank can pause execution and ask for additional documents before releasing the funds, because it may decide that it needs more comfort on the purpose and legitimacy of the transaction under its internal controls.

Typical requests can include the underlying contract or statement of work, invoices, proof of delivery/performance, an explanation of the business purpose, and information on the beneficiary and (where relevant) the beneficial ownership or corporate structure of the recipient.

The bank can route the payment through manual review queues, extending processing times compared with “straight-through processing,” particularly for first-time beneficiaries, unusually large amounts, or payment narratives that do not clearly describe the purpose.

This can create operational knock-ons: late supplier settlement, goods held pending payment confirmation, or service suspension where the vendor operates on strict payment triggers.

The bank can impose internal conditions (for example, requiring richer payment details, stricter invoice descriptors, or pre-approval workflows) as part of its customer specific risk controls. In a corporate group, this can feel like a “policy change” even when the contract with the supplier has not changed.

The bank can refuse to process a specific transaction or decide it will no longer support certain corridors, clients, or business models, as a risk-management choice (again, this is part of the phenomenon discussed under de-risking).

Where this happens, the practical solution is often to adjust the execution setup (alternative banking channel, revised documentation pack, or modified payment/settlement mechanics), while keeping the underlying commercial relationship intact.

Country notes (alphabetical)

Belgium: For Belgium-based payers, treat Vietnam-linked payments as higher-scrutiny items and expect more frequent “why/what/for whom” questions for services, royalties and intragroup charges compared with straightforward goods imports. Strengthen your internal approval trail (business rationale, benefit analysis, pricing support) so you can respond quickly if an auditor or bank compliance team asks for context.

France: For French payers, plan for intensified review of cross-border service/royalty flows and intragroup charges involving Vietnam, with a focus on whether the contractual position matches operational reality (deliverables, control over IP, and where value is created). In procurement and finance, that usually means cleaner statements of work, clearer invoice narratives, and readily retrievable performance evidence.

Germany: Germany has a dedicated legislative framework (the Tax Haven Defence Act) that includes a prohibition on deducting certain expenses connected with “business transactions” with covered jurisdictions, but with express statutory exceptions (for example where the corresponding income is taxed in Germany, or where a CFC add-back applies). Practitioner summaries also describe timing mechanics under which the German deduction prohibition is designed to apply only from the beginning of the fourth year after listing, so for a newly listed jurisdiction the immediate impact is often increased scrutiny and documentation pressure rather than instant across-the-board non-deductibility.

Italy: For Italian payers, Vietnam’s Annex I status is directly relevant to the monitoring and tax-return handling of costs arising from transactions with counterparties in listed jurisdictions, including a deductibility approach linked to “normal value” and the need to separately indicate the relevant costs in the annual income tax return. Operationally, this makes it especially important to keep robust support for service deliverables, pricing and economic rationale (and to ensure the accounting/tax teams can isolate the relevant costs cleanly at year-end).

Malta: For Malta-based groups, assume a higher compliance posture around Vietnam-linked payments (particularly service and IP/royalty-type flows), and expect banks and counterparties to ask more questions on source of funds, purpose of payment and beneficial ownership where relevant. If you use Malta entities in a holding/financing role, pre-empt questions by keeping board materials, contracts and commercial rationale tightly aligned.

Netherlands: For Dutch payers, expect heightened focus on the legal characterisation of payments (service fee vs royalty vs financing return) and on whether intragroup flows reflect where functions and risks sit. From a banking perspective, the Netherlands is a jurisdiction where “bank-ready” documentation packs can materially reduce payment friction on Vietnam corridors.

Spain: For Spanish payers, do not assume that “EU blacklist” status automatically maps one- to-one onto every domestic tax consequence, but do assume it increases practical scrutiny by counterparties, auditors and banks. For Spain-based procurement and finance teams, the most effective response is usually operational: improve contracting, invoice narratives and evidence of performance for services and IP-related payments, and ensure intragroup charges have a clear benefit story and allocation logic.

 avv. Federico Vasoli