French list of tax havens (ETNC): the April 2026 order and Andorra

What the order says

The order of 15 April 2026, published in the Journal officiel of 26 April 2026, updates the French list of non-cooperative States and territories. The three removals (Fiji, Samoa, Trinidad and Tobago) take effect on publication; the two additions (Vietnam and the Turks and Caicos Islands) apply from 1 July 2026. The list has 11 entities: American Samoa, Anguilla, Antigua and Barbuda, Guam, Palau, Panama, Russia, the Turks and Caicos Islands, the US Virgin Islands, Vanuatu and Vietnam.

According to the sources consulted, the French list generally follows the European Union list while adding tax good-governance criteria, which explains why Antigua and Barbuda remains on it even though it has left the European list.

And Andorra?

Andorra is not on this list. Two clarifications avoid misunderstandings:

1. Being absent from the list does not settle everything. The notion of privileged tax regime in Article 238 A of the CGI is separate: it compares the tax actually borne with what would be due in France. See holding company and the French tax authorities.
2. Actual residence remains the central issue for a French taxpayer: see leaving France.

Why the list matters

Being on the ETNC list entails aggravated French tax consequences on payments to the entity concerned. That is therefore not the case for Andorra, but it justifies checking the list at each update before any transaction. Our comparison of countries for a holding company points out that none of the nine countries compared is on it at the date of the order.