EU strengthens international tax cooperation with Andorra, Liechtenstein, Monaco and San Marino

The amending protocols mark another milestone in the EU's ongoing efforts to improve international tax compliance and to fight tax fraud and tax evasion globally.

The updates enhance the existing 2015 and 2016 agreements by aligning with recent EU and international standards. In particular, they expand the scope of reporting to include specific electronic money products and central bank digital currencies. In addition, they strengthen the due diligence and reporting requirements to facilitate the use of information for tax administrations and limit burdens on financial institutions. These changes have already been implemented in the EU by means of an amendment of the Directive on Administrative Cooperation (DAC). Moreover, the amending protocols ensure that the information exchanges continue to take place in accordance with EU rules on data protection.

The four jurisdictions are close neighbours of the EU and have important economic ties to the Member States. It is therefore imperative that effective measures are in place to prevent tax fraud, and evasion, and to ensure a level playing field.

Signing the amending protocols on behalf of the EU, Gerassimos Thomas, Director-General for Taxation and Customs Union, remarked:

"Today we enhance our long-standing administrative cooperation with Andorra, Liechtenstein, Monaco and San Marino on the exchange of financial account information. These agreements underscore the EU's commitment to transparency and international cooperation. By updating and aligning the agreements with revised EU and OECD standards, we are enhancing tax compliance and ensuring a level playing field internationally."

Gerassimos Thomas, Director-General for Taxation and Customs Union

In addition to these amending protocols, the amending protocol to an agreement in the same area between the EU and Switzerland will be signed in the coming weeks. All amending protocols are expected to enter into force on 1 January 2026, following the completion of the respective ratification procedures.

Background

Between 2015 and 2016, the EU signed and concluded agreements with Andorra, Liechtenstein, Monaco, San Marino and Switzerland which provide for the reciprocal automatic exchange of information on financial accounts between Member States' tax administrations and those of the five jurisdictions concerned, in conformity with the Common Reporting Standard (CRS) developed by the Organisation for Economic Cooperation and Development (OECD). This standard was implemented within the EU, for exchanges between Member States' tax administrations, through the Directive on Administrative Cooperation (DAC). In 2022, the OECD adopted some changes to the CRS, which led to the need to update the EU agreements.

In May 2024, the Council mandated the Commission to commence negotiations with the five jurisdictions to amend the EU agreements. The proposals to authorise the Commission to sign the amending protocols, on behalf of the EU, were unanimously adopted by the Council on 10 October 2025.

These amendments support improved tax compliance and are expected to enter into force on 1 January 2026, reinforcing the EU's role in shaping fair and transparent international tax practices.

More information

Council Decisions on the signing of the Amending Protocols to the Agreements between the EU and Switzerland, Liechtenstein, Andorra, Monaco and San Marino on the automatic exchange of financial account information to improve international tax compliance

DAC8 - Taxation and Customs Union - European Commission