Samoa Removed from EU Blacklist and Updates on Tax and Corporate Regime
Samoa was officially removed from European Union’s list of non-cooperative jurisdiction (the “EU blacklist”) on 17 February 2026 for tax purposes after implementing reforms of tax and regulatory framework in line with international standards to combat tax evasion and improve tax transparency.
Below is an overview of the key tax and corporate updates for the business operating through Samoan structures.
AEOI Compliance
Samoa continues to align its tax filing obligations with international standards. Samoa implements the Automatic Exchange of Information (“AEOI”) under the Common Reporting Standard (“CRS”), which sets out the due diligence and reporting requirements for Samoan entities:
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All Samoan entities must comply with annual AEOI requirements by self-classifying as either a Reporting Financial Institution (RFI) or a Non-Financial Entity (NFE).
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NFE must further identify whether it is an Active NFE or a Passive NFE.
Under CRS guidelines, financial details regarding Passive NFEs and their ultimate controlling persons are automatically reported and exchanged with other jurisdictions participating in AEOI.
Tax & Corporate Regime Reforms
In January 2026, Samoa enacted the Miscellaneous (Removal of Tax Exemption for International Companies) Amendment Act 2026, officially scheduling the new tax and corporate regime to take effect on 1 January 2028. The reform completely abolishes the income tax exemption to International Business Companies (IBCs). Instead, Samoa will adopt a territorial tax system. Foreign-sourced income will remain subject to zero-tax treatment. Local income will subject to tax. Companies engaging in relevant activities must establish appropriate economic substance in Samoa. Income derived locally must meet these substance requirements to qualify under the territorial framework.
What Entities Should Do Now
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Review your current Samoa structure to determine whether the company is an RFI, Active NFE or Passive NFE.
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If privacy, security or other significant concerns exist (such as risks to personal safety or sensitive commercial interests), contact your Relationship Manager and Tax Adviser promptly to discuss options, including potential for group restructuring.
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Maintain accurate and up-to-date Company records including financial records to ensure smooth handling of regulatory reporting requirements.
Should you require assistance evaluating your Samoan corporate structure or handling CRS classification, please reach out to your Relationship Manager or our advisory team.
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