On September 22, 2026, El Salvador’s General Directorate of Internal Taxes (DGII) issued the “Guidance to Facilitate the Identification of Countries, States or Territories with Preferential Tax Regimes and Their Tax Treatment” applicable to fiscal year 2027.
The guide was issued pursuant to Article 62-A of the Tax Code, which requires the Tax Administration to publish on the Ministry of Finance’s website, no later than September, the list of countries, states or territories classified as low- or no-tax jurisdictions, commonly known as “Tax Havens.”
The provisions contained in the guide will apply throughout fiscal year 2027.
The 2027 Guide brings significant changes. The most relevant is the removal of 31 jurisdictions from the low- and no-tax lists while, unlike in previous years, only two are added. In addition, eight jurisdictions move from no-tax to low-tax status, and twenty that were classified as low-tax in 2026 now appear on both lists.
I- Main changes for 2027
- Low-tax jurisdictions
Iraq and the Mariana Islands have been added to the list.
In addition, Brunei Darussalam, Campione d’Italia, Curaçao, Saint Helena, Ascension and Tristan da Cunha, Seychelles, the U.S. Virgin Islands, as well as Delaware and Florida (USA), which were on the no-tax list in the 2026 Guide, have been reclassified as low-tax territories.
Meanwhile, Botswana and Malta are no longer on the low-tax list.
- Jurisdictions removed from the no-tax list
The 2027 Guide removes the following jurisdictions from the no-tax category: Anguilla, Aruba, the Bahamas, Bahrain, Belize, the British Virgin Islands, the Cayman Islands, Grenada, Guernsey, the Isle of Man, Jersey, Liberia, the Marshall Islands, Monaco, Montserrat, Nevada (USA), Qeshm (Iran), Saint Kitts and Nevis, Saint Lucia, Saint Vincent and the Grenadines, Samoa, South Dakota (USA), Texas (USA), Trinidad and Tobago, the Turks and Caicos Islands, the United Arab Emirates, Vanuatu, Washington and Wyoming (USA).
- Jurisdictions on both lists
Another noteworthy aspect is that twenty jurisdictions appear on both the low-tax and no-tax lists for 2027, including Lebanon, Liechtenstein, Luxembourg, Mauritius, the Netherlands, Puerto Rico, Qatar and Saudi Arabia. The guide does not expressly explain the reasons for this dual classification, although it maintains the possibility that certain regimes or entities within the same jurisdiction may receive different treatment depending on their tax characteristics.
II- Criteria that remain unchanged
Among other provisions, the guide maintains the position that neither the OECD nor the FATF publishes exhaustive lists of tax havens, since the work under Action 5 of the BEPS Action Plan is aimed at identifying harmful tax regimes and seeking their abolition.
It also reiterates that the No-Tax or Low-Tax lists (as applicable) include, even if not expressly classified as such, all entities that:
- Enjoy an exemption from Income Tax or other similar levies, or are subject to a tax calculated on income or net taxable income that is less than 80% of the Income Tax that would be payable in El Salvador; or
- Are covered by law or Administrative Provision under a preferential low- or no-tax regime, such as holding companies, principal companies, auxiliary or mixed companies, service companies, finance branches or financial power, family wealth management companies, Multinational Company Headquarters (SEM), international trusts (fideicomisos), trusts, Limited Liability Companies (LLC), international financial leasing companies, Private Interest Foundations, International Business Corporations (IBC) and other similar entities.
In this context, reviewing and updating these lists is essential to identify the tax implications of transactions in a timely manner and to prevent contingencies arising from the application of Transfer Pricing rules, withholding obligations and deductibility limitations under Salvadoran law. Our tax team is available to analyze the impact of these changes on your operations. For more information, please contact us at taxelsalvador@consortiumlegal.com