Since the end of 2017, the Council of the European Union has been drawing up a so-called blacklist of non-cooperative tax states. It started as a so-called "name and shame" list, but otherwise had no impact.

This changed: the Council of the EU wants Member States to use tax measures to damage business relations with such states. The aim is to avoid business relations with these states altogether. After Luxembourg (legislative process here has already been completed since 2020), Germany also has adopted its Combating Tax Avoidance and Unfair Tax Competition Act (Gesetz zur Abwehr von Steuervermeidung und unfairem Steuerwettbewerb) this year. The law is applicable from 1 January 2022.