EUROPEAN COMMISSION Brussels, 14.12.2022 SWD(2022) 406 final COMMISSION STAFF WORKING DOCUMENT Final evaluation of Regulation (EU) No 1286/2013 of the European Parliament and of the Council of 11 December 2013 establishing an action programme to improve the operation of taxation systems in the European Union for the period 2014-2020 (Fiscalis 2020) and repealing Decision No 1482/2007/EC

Accompanying the document REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on the final evaluation of the Fiscalis 2020 programme {COM(2022) 717 final}



Table of contents Glossary 1.Introduction 1.1.Purpose and scope of the evaluation 2.What was the expected outcome of the intervention? 2.1.Description of the intervention and its objectives 2.2.Point(s) of comparison 3.How has the situation evolved over the evaluation period? 3.1.Current state of play 3.2.Follow-up on the recommendations of the mid-term evaluation and raising programme awareness 4.Evaluation findings 4.1.Effectiveness - to what extent was the intervention successful and why? 4.1.1.To what extent has Fiscalis 2020 enabled the secured exchange of information, supported administrative cooperation and enhanced participating countries administrative capacity? 4.1.2.To what extent has, Fiscalis 2020 helped to implement Union taxation law? 4.1.3.To what extent has Fiscalis 2020 supported the fight against tax fraud, evasion and aggressive tax planning 4.1.4.To what extent have Fiscalis 2020 resources produced the best possible results at the lowest possible cost? 4.1.4.1.Costs compared to benefits associated with Fiscalis IT systems 4.1.4.2.Costs compared to benefits associated with Fiscalis joint actions

4.1.4.3.Training activity costs compared to benefits 4.1.4.4.Scope to maximise efficiency 4.1.5.To what extent is Fiscalis 2020 coherent with broader EU policies 4.2.How did the EU intervention make a difference (value added)? 4.2.1.EU added value of Fiscalis 2020 IT systems 4.2.2.EU added value of the Fiscalis 2020 joint actions 4.2.3.EU added value of the Fiscalis 2020 training activities 4.2.4.Likely impact if hypothetically Fiscalis was discontinued 4.3.Is the intervention still relevant? 4.3.1.Challenges and priorities in the field of taxation 4.3.2.Extent to which Fiscalis 2020 met tax authorities’ needs 4.3.3.Extent to which Fiscalis 2020 met economic operators’ needs 4.3.4.Extent to which Fiscalis 2020 met public needs 5.Conclusions and lessons learned Annex I: Procedural Information Annex II. Methodology and analytical models used in the final study Approach Evaluation questions Overall methodological framework Programme level evaluation

Data collection and analysis Desk research Stakeholder consultations Data analysis Case study selection Triangulation Conclusions and lessons learned Limits to the evidence base and robustness of findings Annex III. Evaluation matrix and, where relevant, details on answers to the evaluation questions (by criterion) Annex IV. Overview of benefits and costs and, where relevant, table on simplification and burden reduction. Annex V. Stakeholder consultation – synopsis report Stakeholder consultation activities – methodology and approach Interviews Programme level interviews Case study consultation activities Public consultation Challenges and mitigation strategies Key findings per evaluation criteria Effectiveness Efficiency

42.1. Description of the intervention and its objectives As said, the Fiscalis 2020 programme was set up by Regulation (EU) No 1286/2013 of the European Parliament and of the Council of 11 December 2013 establishing an action programme to “improve the proper functioning of the taxation systems in the internal market by enhancing cooperation between participating countries, their tax authorities and their officials”. The general objectives of the EU taxation programme are to facilitate the coherent implementation of EU taxation law and support the fight against tax fraud, tax evasion and aggressive tax planning. This should be achieved, by enabling secure information exchange and storage, supporting administrative cooperation and enhancing the tax authorities’ administrative capacity (specific objectives). The Fiscalis programme is an ongoing, continuously growing and adapting programme. The Fiscalis 2020 programme was built on predecessor programmes. The first programme was called Matthaeus-Tax, started in October 1993 and ran until end-December 1995. Rebranded Fiscalis, there have now been four Fiscalis programmes, including the one evaluated here: the first Fiscalis programme (1998-2002); the second Fiscalis programme (2003-2007); the third Fiscalis programme (2008-2013) and the fourth Fiscalis programme (2014-2020), or Fiscalis 2020, evaluated here. 35 countries fell within the Fiscalis 2020 framework: the 27 EU Member States plus the UK while it was an EU Member State and 7 candidate and potential candidate countries. The Commission manages the programme with assistance from the Programme Coordination Group (responsible for Commission internal coordination) and the Fiscalis 2020 Committee. The Fiscalis 2020 Committee is composed of delegates from each EU Member State. The Programme Coordination Group is composed of DG TAXUD units using the programme and contributes to identifying policy priorities for the Annual Work Programmes, reinforcing coherence between the programme objectives and priorities of the European Commission, monitoring of the programme’s performance and increasing the overall transparency and dissemination of information. 52.2. Point(s) of comparison It is difficult to establish points of comparison because the Fiscalis 2020 programme has a long history and builds upon previous iterations of the programme. As it has been in existence for several years, it is challenging for stakeholders to consider the situation before this started. Take for example, the EIS systems, constituting about 75 % of the programme’s funds. These have long been engrained in national and EU landscapes. In line with the Commission’s commitment to monitor the EU budget and ensure the accountability for value for money, DG TAXUD developed a framework for monitoring the outputs and results of the programme – the Performance Monitoring Framework (PMF). The European Commission PMF monitors the programme’s outputs and results through a results-based monitoring system. It contains an intervention logic, adjustable indicators, data collection schemes and reporting arrangements (see Figure 1). This framework became operational in 2014, following recommendations of earlier evaluations to provide more and better data to assess programme implementation and performance. The PMF outcome has been taken into account to the extent possible in this evaluation. Note that the mid-term evaluation reported then that while ‘…it does already facilitate performance management; the framework is still too fresh to provide insightful benchmarks for the programme’s performance or establish and examine trends’. It is important to note that several issues make it difficult to accurately isolate and estimate the programme’s contribution to the overall EU objectives such as that of smart, sustainable and inclusive growth. First, all programme components play supporting roles. They are not themselves taxation policies and thus disentangling the supporting aspect from the policy implementation aspect and evaluate the programme’s performance vis-a-vis the objectives is challenging. Second, the programme consists of various components, which, while independent in nature, all work towards the same objectives and each of these does not necessarily impact or rely on other components in the same way. Figure 1: Fiscalis 2020 Intervention logic 63. How has the situation evolved over the evaluation period? 73.1. Current state of play The Commission reports on the implementation and performance of the programme annually, through the Annual Progress Reports. All report for 2014 to 2020 are available. The overview of the programme’s implementation presented here is based on the latest available report. As said, the Fiscalis 2020 programme aimed at improving the proper functioning of taxation systems in the internal market, by ensuring the exchange of information, supporting administrative cooperation and enhancing participating countries’ administrative capacity. In this context, the actions under the programme were varied and included the development/ improvement of European information systems, a variety of joint actions, training and external expertise. The Fiscalis 2020 programme had a committed budget of EUR 222 million for the period 2014-2020 (see Table 1 ). 2014 2015 2016 2017 2018 2019 2020 Total 2014-2020 European Information Systems – fiscalis IT systems 23 053 874 24 691 254 23 244 421 24 824 594 22 375 306 24 768 693 25 020 819 167 978 961 75.6% Joint actions other than expert teams and studies 4 555 000 4 230 000 4 300 000 4 540 000 4 912 500 5 576 400 4 923950 33 037 850 14.9% Joint actions - studies and communication 2 184 539 1 375 690 1 640 916 1 898 800 1 867 658 520 372 350 232 9 838 207 4.4% Training 908 585 600 003 1 205 600 - 1 352 000 1 374 000 1 483 000 6 923 188 3.1% Joint Actions - expert teams - - 988 040 519 915 899 585 330 000 1 165000 3 902 540 1.8% External experts 75 000 70 000 70 000 70 000 70 000 - 50 000 405 000 0.18% TOTAL 30 776 998 30 966 947 31 448 977 31 853 309 31 477 049 32 569 465 32 993 001 222 085 746 100 % Source: Fiscalis 2020 – Progress Report 2020 Notes: 1. The table compares committed amounts since the programme’s launch, as the actual expenses are not finalised for all previous years. Budgetary year X covers from 01/04/X to 31/03/X+1; 2. Appropriations may be higher when using foreseen financial contributions from candidate and potential candidate countries participating in Fiscalis 2020.

The vast majority of Fiscalis 2020 funding, 75.6% (about EUR 168 million), went into the development and operation of the EIS systems, followed by the organisation of joint actions other than expert teams and studies, then studies and communication, then training, then expert teams and finally external experts (see Table 1 ). European Information Systems (EIS) Fiscalis supports the development of EIS which in turn can secure information exchange, support administrative cooperation and enhance participating country authorities’ administrative capacity. EIS represent a large share of the funding and comprise many systems. Here is a subset of those that we will be looking at in more detail in this evaluation: ·CCN/CSI - CCN/CSI is the backbone to Fiscalis IT systems. It provides the hardware and software infrastructure to implement multiple IT systems and applications. ·eFCA - The e-forms enhanced tax officials’ capacity by providing national tax administrations a homogenous information exchange format. ·EMCS - With the EMCS, EU customs authorities can monitor the movement of excise goods under duty suspension within the EU. ·TIN - Created to ensure effective use of exchanged information by improving taxpayers’ identification through their TIN is essential. ·MOSS - The MOSS was created to reduce the administrative burden of compliance with VAT rules in cross-border sales for economic operators and eased the logistics of collecting VAT for tax officials. ·DAC 1-6 systems - The DAC systems were implemented to support Member States in the Automatic Exchange of Information. ·TNA - TNA improved tax administrations’ capacities through the Eurofisc network with advanced data analytics and efficient data sharing and its open-source software IT system. It replaced previously labour-intensive exchange via Excel tables. ·TEDB - This database provides information on all major taxes in Member States, facilitating information exchange. Joint Actions Eligible joint actions for which the Fiscalis 2020 programme could fund, provided certain conditions were met, were the following: a. seminars and workshops; b. project groups, generally composed of a limited number of countries, operational during a limited period of time to pursue a predefined objective with a precisely described outcome; c. bilateral or multilateral controls and other activities provided for in Union law on administrative cooperation, organised by two or more participating countries, which include at least two Member States; d. working visits organised by the participating countries or another country to enable officials to acquire or increase their expertise or knowledge in tax matters; e. expert teams, namely structured forms of cooperation, with a non-permanent character, pooling expertise to perform tasks in specific domains, in particular in the European Information Systems, possibly with the support of online collaboration services, administrative assistance and infrastructure and equipment facilities; f. public administration capacity-building and supporting actions;

g. studies; h. communication projects; i. any other activity in support of the overall, specific and operational objectives and priorities set out in article 5 and 6 of Regulation (EU) 1286/2013, provided that the necessity for such other activity is duly justified. Over 1500 joint actions and multiplying events took place during the 2014-2020 period as under one action, multiple events may be organised. Project groups, workshops and multilateral controls (MLCs) had the most weight on the budget in the funding period, while working visits had the highest number of actions. The overview also shows that workshops and project groups tend to be more cost-intensive per action, while working visits consume less per action. In total more than 30,000 participants (instances of participation as the same person can attend more than one action) attended the joint actions (see Figure 2 ). The numbers of participants in the Fiscalis 2020’s joint actions remained at a high constant level especially after 2015. On average for the 2014-2020 period there were above 4300 participations/year. This compares to the evolution of in the previous programming period which saw a gradual dip that spilled into 2014. The low 2014 participation was attributed to the delayed transitioning to the Fiscalis 2020 programme which became operational only from April 2014. Following a larger and more stable performance over the duration of the Fiscalis 2020 compared to its predecessor, participation dipped again in 2020 this time due to the COVID-19 pandemic and consequent measures leading to an interruption of activities for some months. These have gradually resumed in a different, on-line format. The stakeholders’ community adapted to the new working methods (but with a lag which naturally had an impact on the budget consumption). Despite the pandemic, on average, the Fiscalis 2020 final joint action attendance for the whole period was about 4300 participants a year and higher than the average attendance observed during the mid-term evaluation (around 4200 participants per year). Figure 3 shows the total number of participants per action type. Project groups represent by far the largest number of instances of participation of taxation officials in the programme. This is mainly due to the repeated nature of these types of joint actions, where individuals who participate often attend several meetings over time, sometimes lasting the entire funding period. By comparison, the nature of other joint actions, e.g. working visits, is such that they typically involve just a few officials. Workshops and multilateral controls also register a high number of instances of participation, due to both a high number of actions (especially for multilateral controls) and many instances of participation per action. Source: DG TAXUD ART data Source: DG TAXUD ART data Participation varies by country (see Figure 4 for 2020), and across the period. In 2020, Germany was in the lead followed by Sweden and Italy. Overall, there is a much lower number of non-EU country participants.

Source: DG TAXUD ART data Training The Commission procured 267 EU eLearning modules, with courses that mainly focus on training officials to use the EMCS and on various VAT, fraud and refund related topics. The training modules included webinars, eBooks, a Learning Management System ( Customs and Tax EU Learning Portal ), and European Competency Frameworks for Customs and Taxation, the first ‘EU Competency Framework for the tax profession’, the TaxCompEU￼ training material. The Commission also organised 141 skills and competences training sessions for IT systems such as VAT refund, EMCS, VIES or MOSS for tax officials. The majority of the Fiscalis 2020 training budget was allocated to eLearning modules. These modules trained more than 130,000 participants from tax authorities and almost one million additional people from businesses and public.

83.2. Follow-up on the recommendations of the mid-term evaluation and raising programme awareness The Fiscalis 2020 mid-term evaluation outlined 13 recommendations to strengthen and improve the programme and future funding phases (see Table 2 and Annex VI). Five of the recommendations identified the Commission’s DG TAXUD as the sole responsible actor, one with other Commission services, five as having shared responsibility with national administrations and two where national authorities were the main actor. Of the 11 recommendations where the Commission was asked to act, 8 were to cover both the 2014-2020 and the subsequent funding programmes and 3 were relevant for the following programme. In response, the Commission services (DG TAXUD) developed an internal action plan setting out 13 action areas corresponding to the recommendations, with 48 sub-actions outlining how to address or, in the case of those identified for national administrations only, support the implementation of the mid-term evaluation recommendations. This section briefly lays out progress made in implementing the Action Plan, based on DG TAXUD interviews. The mid-term evaluation concluded at the end of 2018 and the action plan was adopted in October 2019. As such, there was not much time for major change to occur and thus many recommendations will relate to the 2021-2027 programme period and will be completed during 2022. Further, many recommendations and actions require active participation and cooperation by Member States’ or national programme coordinators, and thus go beyond the Commission and DG TAXUD’s sole control. Despite these caveats, the state of play by March 2022 regarding progress in addressing the recommendations and implementing the various actions under each recommendation can be seen below (see Table 2 and Table 3 ). As can be seen the vast majority of the recommendations has been addressed as the vast majority of actions in the action plan have been implemented (37 out of 48 can be considered implemented). Actions in progress or yet to be implemented are largely linked to ‘Monitoring and reporting’ or Communication. No. Recommendation Responsible actor Status 1 Make more practical use of the Annual Work Programme projects and consider multi-annual programming DG TAXUD Implemented 2 Designate long-term, platform-like joint actions as such, so that appropriate criteria can be defined for funding applications and monitoring of such actions DG TAXUD Implemented 3 Refine strategy for development and promotion of elearning modules DG TAXUD & national administrations Implemented 4 Investigate ways to improve the technological platform for the delivery of elearning modules DG TAXUD & national administrations Implemented 5 Improve the procedures for the translation, localisation and updates to elearning modules DG TAXUD & national administrations Implemented 6 Increase coordination with other EU programmes DG TAXUD & other DGs In progress 7 Optimise the procedures and resources for the implementation of joint actions DG TAXUD & national administrations Implemented 8 Streamline the monitoring system so that it meets actual needs while reducing administrative burdens DG TAXUD Implemented 9 Develop a more coherent approach to assessing programme performance DG TAXUD In progress as several actions were relevant for the programme that started in 2021 10 Improve reporting and information-sharing tools DG TAXUD Implemented 11 Increase senior-level buy-in and political will National administrations In progress 12 Communicate more actively about the possibilities of the programme National administrations In progress 13 Review strategy for dealing with economic operators and citizens DG TAXUD & national administrations Not started



No. Recommendation Total no of actions Not started In progress Implemented Programming and design subtotals 13 0 1 12 1 Make more practical use of the Annual Work Programme projects and consider multi-annual programming 4 0 1 but not EU level action 3 2 Designate long-term, platform-like joint actions 2 2 3 Refine strategy for development and promotion of elearning modules 2 2 4 Investigate ways to improve the technological platform for the delivery of elearning modules 3 3 5 Improve the procedures for the translation, localisation and updates to elearning modules 2 2 Implementation subtotals 10 1 1 8 6 Increase coordination with other EU programmes 6 1 discarded 1 4 7 Optimise the procedures and resources for the implementation of joint actions 4 0 0 4 Monitoring and reporting subtotals 18 3 0 15 8 Streamline the monitoring system so that it meets actual needs while reducing administrative burdens 6 0 6 9 Develop a more coherent approach to assessing programme performance 7 3 postponed / for evaluation 4 10 Improve reporting and information-sharing tools 5 5 Communication subtotals 7 4 1 2 11 Increase senior-level buy-in and political will 2 0 1 1 12 Communicate more actively about the possibilities of the programme 3 2 postponed 1 13 Review strategy for dealing with economic operators and citizens 2 2 postponed Total 48 8 3 37 Note that the Commission also monitors programme awareness. The Commission therefore runs a programme poll every 18 months to measure familiarity and networking levels in the programme. It is conducted in participating countries’ tax administrations and invites programme participants and non-participants to take part. The last programme poll ( Table 4 ), conducted end-2019, shows declining awareness since 2016 (59 %) to 45 % in 2019. The results are also now below the 2011 baseline (66 %) and has some way to go to meet the target (>75 %). Some caution is needed when comparing the results of the pools as the 2019 programme poll targeted a larger audience within the national administrations . This may help explain the lower awareness rate. Several communication actions had already taken place at the initiative of the Commission (these included for example the use of new communication tools and channels and a common effort between the EU and national programme teams to ensure a wider distribution of information on the programme to the potential beneficiaries). Nevertheless, it was felt that there was an important potential for further raising awareness about the programme at the level of national authorities. In this context, in 2019, a new communication strategy was launched by DG TAXUD. Indicator Baseline 2011 Target Mid 2015 End 2016 Mid 2018 End 2019 Target audience awareness of the programme 66% >75% 54% 59% 48% 45% Source: Fiscalis Annual Progress Report 2020 94. Evaluation findings 104.1. Effectiveness - to what extent was the intervention successful and why? When evaluating effectiveness, efficiency and coherence we look at the Fiscalis 2020 as whole and how its components contributed to achievement of objectives. It considers per objective, the IT systems that are part of the EIS, joint actions and training that were implemented and assesses their success, and to what extent observed results could be attributed to the programme rather than external factors.

114.1.1. To what extent has Fiscalis 2020 enabled the secured exchange of information, supported administrative cooperation and enhanced participating countries administrative capacity? This evaluation question covers the Fiscalis specific objectives of (1) securing exchange of information; (2) supporting administrative cooperation; and (3) enhancing participating countries tax authorities’ capacity so as to reduce administrative burden and taxpayer compliance costs. The Fiscalis Performance Management Framework (PMF) includes useful indicators on EIS, administrative cooperation and administrative procedure sharing. The annual progress reports provide indicators on how Fiscalis actions enhanced tax officials’ administrative capacity, through sharing administrative guidelines and procedures as well as enhancing authorities’ staff, skills and competences. As said, Fiscalis supports the development of EIS which in turn can secure information exchange, support administrative cooperation and enhance participating country authorities’ administrative capacity. In so doing, they enable authorities and economic operators to reduce the time and resources required to carry out activities such as exchanging information or files, identifying taxpayers and collecting and analysing data and provide tax officials time to perform additional activities. Key EISs supporting these objectives and their functionalities are listed in Table 5 . IT structure/ system Link to specific objective CCN/CSI CCN/CSI is the backbone to Fiscalis IT systems. It enhances national tax authorities’ administrative capacity, cooperation and information exchange by providing a hardware and software infrastructure to implement multiple IT systems and applications. eFCA The e-forms enhanced tax officials’ capacity by providing national tax administrations a homogenous information exchange format. It thereby reduced information exchange burden by harmonising procedures for exchanging information. EMCS With the EMCS, EU customs authorities can monitor the movement of excise goods under duty suspension within the EU. It reduced the administrative burden as it replaced the paper-based administrative documents with electronic data exchange. The EMCS secures information exchanged between Member States. TIN To ensure effective use of exchanged information, improving taxpayers’ identification through their TIN is essential. The TIN enhanced administrative capacity, cooperation and information exchange by facilitating the matching of data received from other tax administrations through its introduction of automatic data matching processes. MOSS The MOSS reduced the administrative burden of compliance with VAT rules in cross-border sales for economic operators and eased the logistics of collecting VAT for tax officials. DAC 1-6 systems The DAC systems were implemented to support Member States in the Automatic Exchange of Information. By design, they contribute to supporting administrative cooperation and exchange of information and national tax authorities’ capacity to exchange data on registered inhabitants’ income (cross border taxpayers) in other Member States. TNA TNA improved tax administrations’ capacities through the Eurofisc network with advanced data analytics and efficient data sharing and its open-source software IT system. It significantly reduced the administrative burden compared to the previously labour-intensive exchange via Excel tables. TEDB This database provides information on all major taxes in Member States, facilitating information exchange. Take the CCN, for example, as the backbone IT infrastructure securing information exchange. It was available 100 % of the time according to the evaluation. The data exchange volume via the system steadily increased, reaching 32.23 terabytes in 2019 compared to just 4.3 terabytes in 2014 . Clearly, secure information exchange increased over time, though this is also because of the growing number of EISs (28 taxation systems in 2020 compared to 20 in 2014). Similar trends were observed for specific EIS (see Box 1 ). Overall, the systems helped Member States communicate with each other securely and efficiently in areas of mutual interest, thereby enhancing collaboration. In addition, 9 out of 11 interviewed Fiscalis coordinators of EU countries explained that IT systems have modernised and harmonised their systems information exchange procedures and in turn improved their work efficiency and capacity. Among the IT systems case studies followed by the external contractors, the MOSS stands out for reducing administrative burden for economic operators and tax officials (see Box 2 ). MOSS: 992,292 messages exchanged in 2020, compared to 689,839 messages in 2017 (+44%). During 2015, the number of messages exchanged exceeded 2 million, but is explained by the system being new at the time and there being many technical error messages, and missing information in messages requiring new ones be sent. DAC1/DAC2: 14,000 messages were exchanged via DAC1 in 2020, compared to 12,800 messages in 2017 (+9 %). Compared to 2018 (the first full year of operation), when 14,100 messages were exchanged, the frequency remained quite steady. Through DAC2, 29,700 messages were exchanged in 2020, compared to only 4,600 in 2017 (+545 %) and 24,700 in 2018 (+20 %) . MOSS reduced economic operators and national tax administrations administrative burden Suppliers providing telecommunications, broadcasting and electronic services administrative burden decrease stems from not having to register and file for VAT in every Member State where their services are consumed, but instead using a single electronic portal and dealing with only one VAT administration. MOSS increased compliance among businesses and drastically reduced their compliance costs when filing VAT for cross-border sales. Compliance costs for businesses that use the MOSS are 95 % lower compared to those not using it. This resulted in savings of about EUR 500 million for businesses using MOSS (Union and non-Union scheme). This is a 10 per year savings factor (EUR 434) using vs (EUR 5,203) not using MOSS. The MOSS also lessened tax authorities’ administrative burden as it eased national tax authorities’ VAT collecting logistics and transmitting to Member State of consumption (MSC). While it is early to make conclusions about the TNA, the majority of surveyed TNA users reported that TNA decreased the administrative burden, associated with the previous way of exchanging data, and that they had more time to dedicate to analysis . Under the DAC, all interviewed tax authorities agreed that the Automatic Exchange of Information under DAC1/DAC2 significantly enhanced their capacity to exchange information with other Member States. Table 6 reports the joint actions followed regarding these sub-objectives specifically. It can be seen that about 500 events took place on enhancing administrative capacity, more than 300 on secured information exchange and more than 600 on administrative cooperation. Working visits were one type of action often used through which officials could acquire or increase tax expertise or knowledge. Member States also exchanged tax knowledge and experiences through project groups, often used to discuss, develop and implement EIS. Workshops, although used less frequently, sought to improve tax administrations’ procedures. Capacity building actions mainly consisted of technical assistance to a few Member States. They used less to enhance administrative capacity because it is only used in a smaller number of Member States and initiated by the Commission. Multilateral controls (MLCs) and PAOEs are examples of direct administrative cooperation between tax authorities. Note that MLC processes are usually resource intensive and require adequate support to be done efficiently and effectively. Hence, Member States can request funding under the Fiscalis programme budget. In the case of MLCs, the Fiscalis programme finances the collaborative aspect of this type of joint action (e.g. a coordination meeting between participating country authorities or to finance transport to facilitate cross border simultaneous controls). In other words, Fiscalis provides financial support for participating countries to come together – if the action is under the remit of the Fiscalis programme regulation of course as set above – but it is the responsibility of the participating countries to organise the action. At no stage is the Commission involved in such procedures. Nor does it have access to any information exchanged during those procedures. They are conducted solely by tax authorities of Member States. The involvement of the Commission is limited to approving the financing under the Fiscalis programme of collaborative activities supporting the multilateral control proposed by the tax administrations. While less common, there were working groups and seminars for specific IT systems or for sharing EU taxation law information. On average 95 % of event participants shared working practices, administrative procedures, or guidelines from their national administration programme, and on average 77 % of them declared that an administrative procedure, working practice, or guideline from the programme led to change in their administrations’ working practices. Participants and action managers of joint actions regarding working practices and administrative procedures/guidelines were positive about their effectiveness and usefulness, and largely agreed that the events achieved intended results. In 2020, 88% of action managers of the 61 joint actions that sought to extend working practices and/or administrative procedures/guidelines indicated that they achieved their intended results .

Action specific objective Action type Number of events Number of participants Actual budget (EUR) Enhancing administrative capacity Capacity building 66 119 232,688.77 Project group 166 2076 1,586,070.73 Seminar 1 44 51,646.54 Working visit 229 442 482,586.86 Workshop 33 589 521,180.93 Subotal 495 3,270 2,874,173.83 Securing information exchange Multilateral Control 25 127 80,683 PAOE 3 10 1,902 Project group 268 2,507 1,950,459 Working visit 23 26 28,621 Workshop 8 213 190,873 Subtotal 327 2,883 2,252,538 Supporting administrative cooperation Administrative cooperation 1 15 12,735 Multilateral Control 261 1,456 954,713 PAOE 168 245 127,888 Project group 91 1,130 715,202 Working visit 69 99 97,161 Workshop 41 1,499 1,377,907 Subtotal 631 4,444 3,285,605 Total 1.453 10,597 8,412,316.83 The great majority of interviewed Fiscalis coordinators consider training to be key to enhancing administrations’ administrative capacities. The Commission procured 267 EU eLearning modules, with courses that mainly focus on training officials to use the EMCS and on various VAT, fraud and refund related topics. The training modules included webinars, eBooks, a Learning Management System ( Customs and Tax EU Learning Portal ), and European Competency Frameworks for Customs and Taxation, the first ‘EU Competency Framework for the tax profession’, the TaxCompEU￼ training material. The Commission also organised 141 skills and competences training sessions for IT systems such as VAT refund, EMCS, VIES or MOSS for tax officials. The number of tax officials trained is growing, as more and more tax officials have been trained using EU common materials. Participants’ training quality scores are high (average 72.7 score on a 0-100 scale). Similarly, the share of tax officials who found IT training met their expectations or were useful are consistently over 90 %. Collected evidence suggests that the IT systems that make up the EIS helped Member States secure information exchange, contribute to administrative cooperation and build up administrative capacity. IT tools were also key in enhancing administrative capacity by allowing tax authorities to perform additional actions. The evidence also shows that Fiscalis-funded actions and training enhanced tax authorities’ administrative capacities by enhancing staff skills and competences and sharing administrative procedures and guidelines. All 11 interviewed Fiscalis coordinators of EU Member States were of the view that IT systems, joint actions and training modules would not be available to the same extent without Fiscalis funding, and their functions would be more difficult to undertake. This was supported in interviews with the developers of the Excise Duty Calculator, as it is largely dependent on input from another Fiscalis-funded IT system – TEDB. While some joint actions could have happened, they would not have been possible to the extent and pace. Thus, it is acceptable to say that secured information exchange, administrative cooperation and enhanced administrative capacity would not have been achieved to the same extent without Fiscalis. As mentioned in section 2.2, a separate study has been carried out on the Performance Measurement Framework. The outcome and recommendations of that study have been taken into account in the new Monitoring and Evaluation Framework of the Fiscalis programme (MEF) that is currently being put in place. This will allow the Commission to collect additional evidence and improve monitoring and evaluation of the new cycle of the Fiscalis programme vis-à-vis the objectives of the programme. 124.1.2. To what extent has, Fiscalis 2020 helped to implement Union taxation law? This section looks at how the Fiscalis programme contributed to the general objective of supporting the implementation of Union taxation law. Maintaining Fiscalis EIS systems is a big part of the funding and effort to achieve this specific objective and all IT systems contribute to it. A few are especially relevant ( Table 7 ) because of their role in implementing Union law by enabling secure information exchange, supporting administrative cooperation between tax authorities and enhancing their administrative capacity. Among the joint actions, there were some that were directed at the implementation of Union taxation law specifically (see Table 8 ). Together with the other actions and training they again contributed to a better understanding of EU tax law and better administrative capacity that would in turn lead to a better implementation of EU Law. IT system Link to specific objective CCN/CSI By design, as the backbone to all other Fiscalis IT systems, the CCN contributes to implementing Union law in taxation by enabling secure exchange of information. e-Forms (for direct taxation, VAT, recovery; recently replaced by the e-Forms Central Application eFCA) The e-Forms enhanced tax officials’ administrative capacity by providing a homogenous information exchange format. It reduced the administrative burden of exchanging information, as procedures for information exchange have been harmonised. EMCS The harmonised EU rules on excise duties, as laid down in Council Directive 2008/118/EC, allow the movement of excise goods under duty suspension. The EMCS, by securing information exchanged between Member States, supports implementing the harmonised rules. TIN To ensure effective use of information exchanged, TIN is essential to better identify taxpayers. It thus supports information exchange and contributes to the implementation of Union law. MOSS The MOSS and 2015 VAT rules of supply changes came about at the same time. Thereby, MOSS directly supported the implementation of VAT rules by making it easier for businesses and Member States alike to comply. DAC 1-6 The DAC IT systems were implemented to support Member States in the Automatic exchange of information and thus supports Member States comply with these Directives. TEDB By providing information on all major taxes in Member States, the TEDB facilitates tax compliance. Specific objective Action type Number of events Number of participants Actual budget (EUR) Support implementing Union taxation law (in general) Communication 14 147 174,406 Multilateral Control 2 0 0 Project group 56 1,237 722,154 Seminar 6 184 281,477 Working visit 58 84 83,310 Workshop 41 1,494 1,214,005 Subtotal 177 3,146 2,475,353 Source: ART data on events. Measuring Fiscalis 2020’s impact on the implementation of Union law in taxation is difficult, as it is difficult to establish a baseline comparison of no Fiscalis programme because of the long history of tax cooperation under previous Fiscalis programmes, and because of the nature of the programme actions vis-à-vis the objective i.e. they are supporting actions.

Joint actions contributed to the objective of implementing Union law, notably through administrative cooperation and administrative capacity building. Joint action created networks between participating tax authorities, which all interviewees considered as having significant added value. Seminars, workshops and project groups that bring together many different Member States were considered useful, as they foster mutual learning and thus better understanding and alignment with legislation. Other actions, such as working visits, were also considered useful, as they tend to be focused on good practices for a specific approach or EIS, thus fostering mutual learning as well. Results from Fiscalis event polls substantiate these generally positive results (each year on average 93% of respondents agreed that their participation in joint actions provided a good opportunity for them to expand their network of (and contacts with) officials abroad). The joint actions that were intended to improve understanding and implementing of Union taxation law were largely considered (very) useful and achieving their intended result. Interviewed candidate and potential candidate countries also appreciated the joint actions for networking opportunities, but felt they were not sufficiently addressing their needs, as actions prioritise EU countries and centred on EISs to which candidate countries have no access (see section 4.3). E-Learning modules also played a role in implementing Union law. For example, a range of eLearning modules were aimed at explaining VAT rules (e.g. key principles of the VAT Directive, how to distinguish VAT territories, what constitutes a taxable person, and which goods and services are subject to VAT, etc.), in addition to training modules that explain the use of IT systems. As they explain the legal basis behind the rules, and how to interpret and implement them, the modules support the implementation of Union law. Although there is no measure of the extent to which they have successfully supported Union law, trained tax officials found them useful and were highly satisfied with them. In fact, their impact went beyond tax administrations. An interviewee explained they used the course material in school visits to educate children on tax issues. It is difficult to fully attribute progress towards implementing Union law in taxation to Fiscalis 2020. However, from the evidence presented above, it can be said that the Fiscalis IT systems, joint actions and training have been used intensively and in turn could have contributed to improving the understanding and the implementation of EU Law, via the secure exchange of information, improving authorities’ administrative cooperation and administrative capacity. The evaluation process here described also indicates that all 11 interviewed Fiscalis coordinators of EU Member States were of the view that IT systems, joint actions and training modules would not be available to the same extent without Fiscalis funding and thus information exchange and cooperation would be more difficult and so would be the functions undertaken by tax administrations. Without Fiscalis 2020, some degree of coordination between authorities would have been likely. However, all interviewed national Fiscalis coordinators as well as national tax officials interviewed as part of the DAC and MOSS case studies felt the level of investment would have been lower and processes would definitely not be as effective and efficient (see Box 3). Fiscalis 2020 thus may have played a significant role in the effective implementation of EU legislation on tax matters. As the EU’s main financial tool for taxation, it is inextricably linked to policymaking. MOSS: provided a single, centralised system through which the traders could, from their Member State of identification declare and pay, in one single return, the collected VAT on all cross-border related transactions and allowing tax authorities to automatically transfer VAT return information and payment to their relevant counterparts, instead of having to communicate bilaterally. The MOSS was imperative for Member States to implement the place of supply rules that was introduced by the Council Directive 2008/8/EC and that entered into application in 2015. It significantly reduced administrative burden compared to a situation in which rules changed without an EU-wide IT system like the MOSS would have forced the traders to register for VAT in each Member State they were supplying such services. Consequently, it helped businesses to comply with EU tax law by reducing their administrative burden compared to a situation where rules changed without such a simplification mechanism. DAC 1/DAC 2: As confirmed by all four interviewed tax authorities, it would have been difficult to implement the automatic exchange of information provided by for DAC1/DAC2 Directives without the support of the Fiscalis programme. Its contribution to CCN is especially pivotal to Member States sharing automatic information. Joint actions also helped Member States improve their Exchange of Information processes within DAC1/DAC2 and implement the Directives nationally, whereas the Fiscalis-funded expert team on DAC2 helped to develop data sharing systems under DAC2. Without Fiscalis, the volume and quality of information exchanged would have been lower, and costs much higher due to the need to develop bilateral agreements. TEDB: Personal income tax and VAT rate information in Member States is available on the Single Digital Gateway via the TEDB. According to those responsible for the Gateway, makes it easier for EU citizens and SMEs, which use this reference tool, to be informed and comply with tax requirements. 134.1.3. To what extent has Fiscalis 2020 supported the fight against tax fraud, evasion and aggressive tax planning One key aspect to look at when evaluating the Fiscalis 2020 programme is its potential contribution to the general objective of supporting the fight against tax fraud, tax evasion and aggressive tax planning. A number of EIS and joint actions were implemented that could directly and indirectly strengthen the fight against tax fraud, evasion and aggressive tax planning. Key EIS and their functionalities that can directly and indirectly support this objective are listed in Table 9 . IT systems Link to specific objective (TNA) TNA fights tax fraud by increasing the Eurofisc network’s operational capabilities with advanced data analytics, efficient data sharing and an open-source IT software system. TNA pursues VAT and missing trader intra-community, fraud schemes. It allows tax officials to pursue a higher number of suspected tax fraud cases. EMCS EMCS monitors excise goods under duty suspension movement within the EU via an electronic Administrative Document (eAD), recording real-time movement between authorised consignors and consignees of alcohol, tobacco, energy products where excise duties still need to be paid. By monitoring movements, illicit activities are less likely to occur. SEED SEED is a European Database of economic operators incorporated into EMCS, matching consignor and consignee excise numbers against the European register of economic operators. It helps to avoid fraudulent activities by verifying traders and consignors as well as monitoring trade flows. VIES and Vies on the Web VIES allows data flows across internal frontiers. It enables companies to rapidly obtain their trading partners’ VAT number confirmations and enables VAT administrations to monitor and control the flow of intra-community trade to detect irregularities. It is a key system to fight VAT fraud allowing Member States to match cross-border transaction information and detect fraudulent activities. eForms VAT VAT eForms ease requesting and receiving information between Member States’ tax officials. They use e-forms to request information from other tax authorities and this allows them to identify tax fraud and evasion risks. DAC 1-6 Under the DAC1-DAC2 regimes, a tax authority receives and sends information automatically (via an Automatic Exchange of Information) to other tax authorities where the taxpayer earns income and/or holds assets. This enables them to fight tax evasion and tax fraud of taxable persons or entities who generate income in other countries. Under the DAC1-DAC6 regimes, tax authorities automatically exchange information on a number of categories of taxation data. This enables them to fight against tax evasion and tax fraud of taxable persons or entities. Several indicators suggest that EISs contribute to strengthening the fight against tax fraud, tax evasion and aggressive tax planning. As previously described, the steadily increasing volume of CCN messages exchanged indicates that tax authorities have been active in exchanging data, which is key in this process. Evidence from two case studies on IT systems suggests that EIS contributed to fighting tax fraud by reducing tax administrations’ administrative burden and facilitating businesses’ VAT compliance (see Box 4 : Case study insights of selected EIS’ contribution to fighting tax fraud, evasion and aggressive tax planning ). The TNA is an automated data-mining tool, which allows quick assessment and reporting of potential cases of Missing Trader Intra-Community (MTIC) fraud. The Eurofisc network uses it and its advanced data analytics and algorithms to quickly and accurately detect potential MTIC fraud for further investigation. The Automatic Exchange of Information (AEOI) under DAC1 provides automatic exchange of five categories of income and assets: employment income, pension income, directors’ fees, income and ownership of immovable property and life insurance products. It also includes provisions for spontaneous exchange of information and exchange of information on request. It also contains provision for Multilateral Controls (MLS) and Participation in Administrative Enquiries (PAOE). DAC2 provides automatic exchange of financial account information on (not corporate) taxpayers’ income earned and accounts held in other Member States. DAC1 is in place since 1 January 2015 and DAC2 since 1 January 2016. How TNA and DAC1/DAC2 and contribute to the fight against tax fraud, tax evasion and aggressive tax planning Despite being implemented only in May 2019, over half of the surveyed Eurofisc liaison officials believed that TNA helped detect and intercept more cases of fraud than ever before. Most of the remaining consulted officials indicated that it was too early to say for sure. It was not possible to estimate by how much fraud detection increased in practice. However, there was general agreement among them that it was effective in detecting fraudulent activities because the quality and scope of the exchanged data had increased, and the administrative burden was reduced. The DAC1/DAC2 case study found that four of the five consulted Member States (BE, FI, PL, SL) generated additional tax revenue from the data exchanged estimated at EUR 6.1 million in 2020 . These additional tax revenues were achieved by taxing taxpayers’ income not previously declared before the information exchange under DAC1/DAC2. This suggests that the exchange of information reduced or at least avoided fraudulent behaviour. Further, the five consulted Member States unanimously acknowledged its deterrent effect as having an important role in reducing tax fraud and tax evasion. Fiscalis-funded expert teams substantially supported the development of IT systems that aim to contribute to fighting tax fraud, tax evasion and aggressive tax planning. Ten expert teams developed the following aspects and tools of EISs: Management of IT collaboration in taxation (MANITC I – IV); Automatic Exchange of Information – DAC2; Transaction Network Analysis (TNA I – TNA II); Mobile Application for EMCS Controls; Excise Duty Calculator; Central Electronic System of Payment for data exchange. Expert teams can play a decisive role in enhancing the development and implementation of some EIS and indirectly fight tax fraud, evasion and aggressive tax planning. The evidence from the TNA case study suggests that the two related expert teams have been instrumental in developing the IT system, and there is some evidence that some more potentially fraudulent cross-border transactions have been identified. The case study on DAC2 also provides indicative evidence in the form of opinions of interviewed Member States, which indicated that the deterrent effect of the Automatic Exchange of Information under DAC2 contribute to fighting tax fraud and tax evasion.

On average, about 44 % of all joint action proposals submitted were linked to fighting tax fraud, evasion and aggressive tax planning and consumed 46 % of the total joint actions’ budget. Under this objective, workshops had the most participants and highest share of the budget (see Table 10 ). Project groups included actions to enhance the capacity of the Eurofisc network, VAT fraud projects and training for MLCs. Where it concerns MLCs, it should be noted that the Fiscalis programme can only financially support the collaborative aspect of MLCs such as coordination meetings involving at least two Member States. During the coordination meetings, in which the Commission never participates, representatives of participating countries are present and exchange information on specific entities and their business relations, to resolve complex taxation cases. If audits are carried out by a national authority alone, the Fiscalis Programme does not provide the funding, as these do not represent a collaborative activity. Other joint actions were working visits, administrative cooperation, presences in administrations and participation in administrative enquires (PAOE). Working visits enable visiting and hosting tax officials to exchange experiences and enhance participants’ tax skills and knowledge. During PAOEs, a Member State’s officials may be present in another’s office during administrative enquires carried out in its territory. During the presence, they may also examine records and interview individuals in the hosting Member State. The distribution of proposals is not geographically balanced and non-EU Member States submitted a much lower share of proposals for this objective. Specific objective Action type Number of events Number of participants Total budget actual (EUR) Support the fight against tax fraud, tax evasion and aggressive tax planning Administrative cooperation 162 1,030 596,350 Multilateral Control 630 3,771 2,316,001 PAOE 42 129 54,541 Project group 435 6,681 5,060,208 Working visit 493 1,734 1,643,019 Workshop 984 10,873 8,304,344 Totals 2,746 24,218 17,974,464 Source: ART data on events. Source: ART data on joint action proposals MLCs are important joint actions for fighting tax fraud, evasion and aggressive tax planning according to most Fiscalis Coordinators. The overall number of operational MLCs grew from 76 in 2014 to 198 in 2019. The number of operational MLCs dropped to 51 in 2020, due to the COVID-19 pandemic. MLC events also increased in the evaluation period, except in 2020 where they reduced for the same reason. The most active MLC event hosts were Germany and the Netherlands, while Eastern European countries were less active. Note that the evaluation only looked at the collaborative aspects of MLCs which is what Fiscalis supports. MLCs have their own legal basis which also stipulates the way information is accessed by different entities Source: ART data on events Based on a survey, Figure 7 shows MLCs average effectiveness rating by MLC coordinators on a scale from 0 “results not achieved” to 4 “results fully achieved”. Indeed, each year, all coordinators of MLCs that took place that year are asked to provide their own assessment of the degree to which the MLCs achieved the results in a survey. One MLC has one MLC coordinator. The average yearly rating increased up to 3.5 in 2020, which suggests that, in general, MLCs’ effectiveness is positive according to MLC coordinators. There is no data on the monetary benefits of MLCs, but the Fiscalis 2020 Progress Reports suggest that they have consistently led to recovered revenue and increased taxpayers’ compliance. Hence, the external evaluation study concluded that they are in general effective regarding this objective. This study did not however assess the quality of each and every MLC conducted. Source: AFF, as reported in the 2020 annual progress report of Fiscalis 2020 (scale of MLC coordinator assessment: 0: not achieved; 4: fully achieved).

The DAC1/DAC2 and TNA case studies found that joint actions are implemented to support the developing, implementing or improving IT systems through project groups, workshops or training sessions. Under the DAC1/DAC2, joint actions were used to exchange best practices and experience among Member States to improve data matching rates, usage quality and statistical reporting. As part of the process of developing and deploying the TNA, three Fiscalis-funded project groups explored its feasibility and implementation and oversaw and assisted its implementation. The work of the first project group informed the work of the expert team, tasked with developing the IT system. Two TNA training sessions were also organised with 55 participants in total, which survey respondents saw as useful . These two examples highlight the synergies between various Fiscalis 2020 activities in developing or improving EIS. To see if the Fiscalis 2020 programme has supported the fight against tax fraud, tax evasion and aggressive tax planning by improving the functioning of taxation systems in the internal market, one can look at the ability of tax systems to collect tax revenue which is the primary source of income to support Member States public policies. On average, and as a share of GDP, tax revenues (which are significantly higher in the EU compared to other advanced economies such as Canada, the US or Japan), constituted about 40.2 % of EU-27 GDP in 2020, following a steady increase since 2015 (see Figure 8 ). This could be evidence that the programme contributed to improve the ability of tax administrations to collect taxes though of course it is difficult to establish causality as increased tax revenues also depend on several other variables including economic growth, tax rates and the tax base. One indicator often used as a measure of the effectiveness of the tax system and tax administrations to collect revenue is the VAT gap indicator for which most EU countries have comparative estimates. It can be seen that there has been a steady decline of the VAT gap from 2014 to 2019 (see Figure 9 ) and a related decline in VAT revenue loss. Such positive developments could be related to policy actions and increased capacity by tax administrations that were supported by the Fiscalis 2020 programme though as said it is difficult to establish the accurate contribution of the programme alone. In other words, evidence shows that tax collection improved and tax fraud and aggressive tax planning levels may have declined on the basis of these (limited number of) indicators. Therefore, it may be the case that the Fiscalis 2020 has supported such developments indirectly through the securing of exchange of information, improving cooperation and administrative capacity. As said, it is difficult to connect trends and developments in tax fraud to Fiscalis 2020 in an exact manner, though qualitative analysis via interviews and case studies suggest that Fiscalis had a positive impact in this regard (see below). Note too, that, in 2019, EU countries lost an estimated EUR 134 billion in VAT revenues which suggests that there is still room for improvement. Source: European Commission, Directorate-General (DG) for Taxation and Customs Union, based on Eurostat and OECD data Source: Centre for Social and Economic Research & Institute for Advanced Studies: Study and Reports on the VAT Gap in the EU-28 Member States: 2020 and 2021 Final Reports All 11 interviewed Fiscalis EU national coordinators believed there is tangible evidence that Fiscalis contributed to the objective of fighting tax fraud, tax evasion and aggressive tax planning. More than half of them saw MLCs as an effective action that produces tangible outcomes. As was explained eight out of fourteen Fiscalis coordinators indicated that MLCs often generate additional tax revenues or uncover tax fraud cases, therefore producing tangible results in the form of additional tax revenue and/or prevented/uncovered tax fraud. Three national coordinators mentioned specific EISs as very effective. In their view, the Automatic Exchange of Information under DAC was very effective as it is being used in MLCs to solve complex cross border business taxation case relations. Data on incomes or financial bank accounts of entities in other countries help national tax administrations perform joint MLC audits. All 14 interviewed EU and candidate countries Fiscalis coordinators stated that the same results could not have been achieved without Fiscalis. They especially highlighted EISs as the main activity that Member States could not have implemented on their own. Two interviewees mentioned the Automatic Exchange of Information under DAC, stressing that a unified approach to sharing data would have been impossible without Fiscalis’ support. On the basis of the evidence collected, it can be concluded that overall, Fiscalis has contributed to fight tax fraud, evasion and aggressive tax planning by financing EISs, joint actions and training that helped tax authorities better avoid, detect and combat fraudulent activities. EIS play an important role in fighting tax fraud, evasion and aggressive tax planning. MLCs also generated tangible effects according to the MLC coordinators, and their effectiveness and efficiency is improved by the EISs for information exchange. Thus, Fiscalis via EISs complemented by joint actions has helped contribute to the fight against tax fraud, evasion and aggressive tax planning though the extent of this contribution is not possible to quantify as it is a supporting instrument and it is difficult to disentangle from policy action. 144.1.4. To what extent have Fiscalis 2020 resources produced the best possible results at the lowest possible cost? When evaluating efficiency, the external study looked at the extent to which allocated programme resources were worthwhile in achieving the intended results. The programme-level analysis relied on cost data (for EIS, joint activities, training activities) provided directly by DG TAXUD or extracted from the Annual Progress Reports, which was compiled and used to answer the relevant evaluation questions. It was complemented with evidence on perceived benefits collected through the programme-level stakeholder consultations and the case study findings. The methodology for evaluating the efficiency of each specific IT system was adapted in in each case study to the specificities of each system (based on their theory of change). Depending on the availability of reliable data, an attempt was made to estimate the costs and benefits, and where possible to monetise them. The latter was only possible to a certain extent for the MOSS, DAC1/DAC2 and TNA case studies. DG TAXUD primarily supplied data on costs. In the case of MOSS and DAC1/DAC2, it was complemented with cost data from previous studies and data provided via interviews, albeit by a small sample of stakeholders. To report on the benefits of each IT system, the analysis relied mainly on interviews with relevant stakeholders. In the case of TNA, this was complemented by a survey, and in the case of DAC1/DAC2 by results of the yearly assessment questionnaires of the Automatic Exchange of Information. The assessment on the ratio between costs and benefits was made by relating to the likely costs of a counterfactual scenario in which the IT systems did not exist, mainly quantitatively. More detail on the methodology followed in each case study is presented in each case study report. As shown in Figure 10 below, EIS made up a large majority (around 75 % per year) of the Fiscalis 2020 budget. Overall, the resource allocation and division remained relatively stable, and most resources budgeted were committed as expected (see Table 11 ). The total budgeted expenses for the 2014-2020 period were EUR 222,666,000 and those committed – EUR 222,085,746.

Source: Fiscalis 2020 Annual Progress Report 2020 2014 2015 2016 2017 2018 2019 2020 European Information Systems 23,053,874 (23,477,000) 24,691,254 (23,450,000) 23,244,421 (22,140,000) 24,824,594 (22,347,000) 22,375,306 (23,141,000) 24,768,693 (22,860,000) 25,020,819 (23,090,000) Joint actions (excl. expert teams and studies) 4,555,000 (4,425,000) 4,230,000 (4,230,000) 4,300,000 (4,300,000) 4,540,000 (4,200,000) 4,912,500 (4,100,000) 5,576,400 (6,196,000) 4,923,950 (5,601,400) Joint actions (expert teams only) N/A N/A 988,040 (1,500,000) 519,915 (650,000) 899,585 (1,530,000) 330,000 (270,000) 1,165,000 (2,070,000) Common training activities 908,585 (1,000,000) 600,003 (1,025,000) 1,205,600 (1,237,000) 0 (1,242,000) 1,352,000 (1,352,000) 1,374,000 (1,374,000) 1,483,000 (1,483,000) Joint actions -Studies, communication and support 2,184,539 (1,800,000) 1,375,690 (2,250,000) 1,640,916 (2,202,000) 1,898,800 (3,300,000) 1,867,658 (1,850,000) 520,372 (1,800,000) 350,232 (698,600) Other expenditure (external experts) 75,000 (75,000) 70,000 (70,000) 70,000 (70,000) 70,000 (70,000) 70,000 (70,000) 0 (70,000) 50,000 (50,000) Total 30,776,999 (30,777,000) 30,966,948 (31,025,000) 31,448,978 (31,449,000) 31,853,309 (31,809,000) 31,477,049 (32,043,000) 32,569,465 (32,570,000) 32,993,000 (32,993,000) Source: Fiscalis 2020 programme Progress Report 2020, Annual Work Programmes 2014-2020 154.1.4.1. Costs compared to benefits associated with Fiscalis IT systems The overall cost for Fiscalis 2020 EIS was EUR 168 million over the period 2014-2020. The development costs (i.e. software development) amounted to EUR 19.6 million (14 %, Fiscalis EIS budget). Additional system costs for testing, infrastructure, maintenance, operations and quality assurance are estimated at EUR 93.2 million (65 %, Fiscalis EIS budget). This is much higher than development costs because many of the systems existed before 2014 and operating costs (infrastructure, data centres maintenance and other expenses, testing and quality assurance) are often more resource intensive. Note that cost details are only available as total costs for the Fiscalis and Customs programmes together. During 2014-2020, these were about EUR 233 million (EUR 33 million for functional and conformance testing and Member State support; EUR 155 million on infrastructure, maintenance and operational costs; and EUR 45 million on quality assurance activities). As 27 % of the IT systems are for Fiscalis 2020 and 26 % are common to both programmes, one can associate around 40 % to Fiscalis 2020. Due to this sharing of contracts between Fiscalis 2020 and Customs 2020, there is no breakdown of costs per IT system, and we cannot provide an overview of the resources allocated to Fiscalis 2020 IT systems per specific objective. Member States also incur costs for acquiring, developing, installing, maintaining and day-to-day operating of the non-Union components of the Fiscalis IT systems. These costs vary significantly between countries and systems, based on the IT infrastructure already in place, the size of the country where it is being implemented and how their tax administration is organised, the local costs of IT support, and so on. It is therefore difficult to estimate the costs associated with this aspect of participating in the Fiscalis 2020 programme, and interviewed coordinators were also unable to provide such estimates. Box 5 presents IT systems cost that were assessed in case studies. They cannot be taken as a representative for other systems and should be seen as examples due to the considerations outlined above. ·MOSS: Average development cost of EUR 2.5 million, ranging from EUR 1-6.5 million. Annual maintenance costs ranged from EUR 100,000-500,000. ·SEED: Developed in the 1990s, have therefore only incurred maintenance costs 2020 programming period. No cost estimates were made available. ·DACs: Compliance cost was EUR 126.6 million for all Member States during 2017-2019. Most (between 82-92 %) were development costs, and maintenance costs were limited. ·TNA: Member States incurred EUR 383,752 for co-financing the Operational Teams (Expert team for Transaction Network Analysis I and II) in the period between 2018 and 2020. ·TEDB: DG TAXUD information shows incurred costs by all Member States for updating the TEDB are around 2.6 FTE a year. However, this varies significantly depending on whether or not changes occurred in the national tax laws or in the database, suggesting workload and related costs could be significantly lower. Other stakeholders (e.g. businesses, financial institutions) can indirectly incur costs for Fiscalis IT systems. For the MOSS, in addition to compliance costs for the 2015 VAT rule changes, a 2016 study estimated the cost to start using the MOSS system. The costs resulted from required changes to billing software logic, capturing additional transactional information, website changes and separate report requirements for MOSS returns . Based on the answers received, the study estimates that the average cost for setting-up the IT systems amount to about EUR 1.2 million. However, there are very large variations across businesses, as the costs identified vary from EUR 8 000 to EUR 10 000 000. As most of the data were provided by large businesses, the relatively high average costs (as well as some of the higher values reported) are most likely related to the size of the businesses. Indeed, some of the businesses provided aggregated data for the entire group (thus including group companies). Such aggregated figures could explain the high variations across countries and some of the highest figures. Under DAC2, financial institutions are obliged to share their clients’ bank account details with the national tax authorities, which required setting-up systems for collecting the data and clients’ agreement to share it. This enables an automatic information exchange on financial account data among EU Member States. The costs borne by financial institutions cannot be provided, as there is no available data, but estimated for the Polish financial sector at EUR 4.4 million. As reported previously, there is clear evidence of the IT systems studied have contributed to the Fiscalis 2020 objectives. Many of the benefits are inherently difficult to quantify (e.g. the extent of tax fraud reduction and Fiscalis IT systems contribution; or tax authorities’ increased administrative capacity). Nevertheless, the case studies conducted as part of this evaluation revealed concrete examples of benefits outweighing costs for specific systems (see Box 6 ). Taken together, the evaluation concludes that there is clear evidence of Fiscalis 2020 IT system benefits outweighing costs. ·MOSS: It is not possible to link additional VAT revenue to the MOSS. MOSS VAT revenue did grow at a much faster rate than overall VAT revenue. This is in part due to a general increase in cross-border B2C supplies of telecommunications, broadcasting and electronic services, but might also signify increased compliance and payment of VAT. The main benefit for businesses and administrations have been simplification, costs for businesses using MOSS are about 95 % lower than costs for businesses not using it (EUR 2,200 vs. EUR 41,626 per business per year). Even if this ratio is inflated because it is based on estimates from 2016, it points towards significant cost savings for businesses using the MOSS. There is consensus among all stakeholders consulted that MOSS investments were worthwhile, because it lowered the administrative burden for authorities and businesses alike, in comparison to a hypothetical situation in which the 2015 place of supply rules were introduced without a system like the MOSS to facilitate their implementation. ·DAC1/DAC2: Information exchange introduced compliance costs and an administrative burden for tax authorities but also increased tax revenue for their fiscal budgets. Although difficult to quantify given a lack of data, the Automatic Exchange of Information estimated an average cost of EUR 1.5 million per Member State per year , compared to an average EUR 1.6 million additional tax revenue per Member State in 2020 (according to those consulted). ·TNA: The majority of surveyed TNA users agreed that the investments and resources dedicated were worthwhile . Initial estimates show that for every 1 EUR spent on the TNA, EUR 1,454 of fraudulent or suspicious transactions were detected. Although it is challenging to conclude how large a share of dubious MTIC fraud transactions identified are followed up on or recovered (this is dependent on the internal processes and available resources of each tax administration) or can be attributed to the TNA rather than Eurofisc liaison officials’ work more generally, those consulted experienced improved efficiency in detecting dubious cases. ·SEED: Although no concrete monetary estimate of costs and benefits are available, SEED reduced tax authorities’ administrative burden by providing a centralised, regularly updated register of economic operators. Without SEED, the process to check excise numbers accuracy and validity would require significant time and human capital effort. ·TEDB: Using the TEDB as an information source for other tools such as the Single Digital Gateway and the Excise Duty Calculator was considered very cost-efficient by the respective developers and was a decisive factor in making a decision to develop the Calculator. While the TEDB is not widely used by economic operators, those interviewed believed that it could be a very cost-efficient source of information on standard and reduced VAT rates for online marketplaces having to collect and remit VAT as a result of the implementation of the VAT eCommerce Package. 164.1.4.2. Costs compared to benefits associated with Fiscalis joint actions Fiscalis 2020 joint actions costs are available at a much more granular level. Expenditure on joint actions (seminars, workshops, project groups, bilateral or multilateral controls, other administrative cooperation activities, working visits, PAOEs and capacity building activities) excluding expert teams and studies amounted to about EUR 33 million. The largest share of resources was spent on project groups, followed by workshops and multilateral controls. As the majority of the costs associated with participation in these joint actions is covered by the Fiscalis 2020 budget (travel costs, costs linked to the organisation of events, daily allowances and accommodation costs), Member States incur very little costs. This is slightly different for third country working visits, where Fiscalis covers travel and subsistence, but organisation costs are borne by the host countries. Because of this, arguably, Fiscalis joint actions benefits clearly outweigh the costs incurred by Member States. However, this might not be the case for candidate and potential candidate countries, as two interviewees suggested. One explained that an evaluation showed their financial contribution to Fiscalis as high considering the extent to which they can participate. Although they see value in participating, they would like access to more aspects of these actions.

In general, the average cost per participant has remained relatively stable with a slight overall decrease, which might signal improved efficiency (see Figure 11 ). There are no clear differences for different types of joint actions. Source: ART data Fiscalis programme poll results each year are overwhelmingly positive, suggesting actions’ benefits are high. The majority of tax authorities interviewed for this evaluation agreed that the benefits outweighed costs. Therefore, it is safe to conclude that joint actions investments were considered worthwhile and cost-effective when considering the costs versus the outcomes achieved. Expert teams, in particular, seemed highly cost-effective. Participation in expert teams is not fully reimbursable by the Fiscalis 2020. While travel and subsistence costs are fully reimbursed, personnel costs are only partly covered (the Fiscalis budget covers 50 % of administrations costs). These expert groups were crucial in the development of some of the Fiscalis IT systems which might not exist in the current setting without them (e.g. TNA, TEDB). To illustrate further the cost-effectiveness of the Fiscalis joint actions, concrete examples from some of the case studies are presented in Box 7 below. ·MOSS: Fiscalis 2020 invested EUR 375,111.43 into MOSS joint actions. With 381 participants at EUR 984.5 per participant, these actions were quite expensive compared to for example DAC1/DAC2 actions. However, the most expensive were the MOSS technical workshops and communication activities by the Commission. They were imperative for the proper system rollout and ensuring businesses were adequately informed, which in turn enabled compliance with 2015 VAT rules. This was recognised by stakeholders and applied again in preparing for the OSS. ·DAC1/DAC2: DAC1/DAC2 joint actions amounted to EUR 689,978.78 for 1,405 participants (i.e. EUR 491 per participant). Stakeholders considered the joint actions, as providing good platforms to further develop the Automatic Exchange of Information and exchange experience and best practice among the countries data use, which is a prerequisite for increased compliance and tax revenue. ·TNA: As the TNA is relatively new, many of the joint actions it implemented were expert team project groups to assess the tool’s feasibility and assist its implementation. Without Fiscalis 2020 funding these project groups, TNA likely would not exist. The costs of the TNA-related joint actions (EUR 246,740) are relatively low compared to the other IT systems and the tool has significant potential benefits. Initial estimates assess that it has contributed to the detection of EUR 5.3 billion worth of fraudulent or suspicious transactions, indicating that investment in the related joint actions is arguably worthwhile. 174.1.4.3. Training activity costs compared to benefits In the period, EUR 6.9 million was committed for common tax training, compared to EUR 8.7 million budgeted (absorption rate, 80 %). The majority of the Fiscalis 2020 training budget (EUR 4.7 million) was allocated to eLearning modules. These modules trained 130,470 individuals from tax authorities and 941,938 additional people from businesses and public. Thus, the training modules cost EUR 4.9 per person trained. Based on the most recent eLearning satisfaction survey, the courses are highly appreciated. Both national administrations and individual users have reported high quality scores on the content, methodology and technology . This was confirmed in this evaluation. The majority of interviewed tax authorities described eLearning as useful and effective in increasing their capacity, as well as being helpful for other stakeholders. More broadly, other Fiscalis training activities taking place as part of project groups or capacity building activities (notably IT trainings) were also considered to have directly increased their administrative capacity and facilitated tax authorities’ coordination and cooperation. 184.1.4.4. Scope to maximise efficiency Fiscalis 2020 mid-term evaluation judged the overall structure and processes for managing the Fiscalis programme as broadly appropriate. Given that they have not recently changed, it can be assumed that this holds true, and it was not a focus of this evaluation. Further, the mid-term evaluation identified ways in which Fiscalis 2020 actually reduced the Commission and participating countries’ administrative burdens, e.g. introducing unit costs for accommodation expenses, which resulted in cost and time savings. However, it identified concerns about the paperwork required to join, initiate and provide feedback on joint actions. Also, limited human resources at national level to adequately respond to requirements led to recommending DG TAXUD to optimise procedures and resources for joint actions and keep workload manageable. This appears to have improved in the latter half of Fiscalis 2020, as no administration considered the burden too high compared to their benefits. No concrete inefficiencies or possibilities to further simplify or reduce the burdens were identified. There are always certain barriers or burdens, for involved, but generally, tax authorities feel that these are balanced with the programme outcomes. 194.1.5. To what extent is Fiscalis 2020 coherent with broader EU policies Under the coherence criterion, we analyse the extent to which the Fiscalis 2020 programme is coherent with broader EU policies. As a first step, this section addresses Fiscalis 2020 coherence with the Commission broader strategic framework, especially in light of changes in Commission priorities since the mid-term evaluation. We then further analyse the relationship between Fiscalis and similar EU funding programmes, as well as its coherence with measures taken in non-EU Member States. As noted during the Fiscalis 2020 mid-term evaluation, its programme action was aligned and coherent to the Commission overall strategic priorities, especially to the Europe 2020 strategy.

Looking at the Commission revised objectives for the 2019-2024 period, a similar conclusion can be drawn. Under the Commission priority “An economy that works for people”, the Commission aims at “…tackling tax abuse, ensuring sustainable revenues and supporting a better business environment in the Single Market.” The Fiscalis achievements under its specific objective to fight tax fraud, evasion and aggressive tax planning (see section 4.1.3) clearly aligns with this Commission strategic objective. Further, the Fiscalis 2020 funded actions are coherent with the Commission priority “Europe fit for the digital age”, under which the Commission aims to modernise public administrations as in the Commission’s eGovernment Action Plan. Actions under the Fiscalis specific objective to enhance administrative capacity of participating countries, especially the development, improvement and implementation of EIS will support this priority. In 2020, the Commission released the Package for fair and simple taxation containing 25 taxation initiatives to support, the recovery from the economic disruption caused by the COVID-19 crisis and the transition into a green and digital economy . Most of the initiatives are still in their preparatory phases and thus fall out of Fiscalis 2020 scope. The new Fiscalis programme will be able to contribute via joint actions to many of these initiatives. Below are relevant initiatives planned for 2021-2023: ·Amendment of 2011/16/EU to include exchange of information on income generate through share and gig platforms (DAC7) and crypto assets (DAC8) ·EU Initiative on VAT in the digital age, to amend the existing VAT directive in line with digital developments; ·Actions to further develop the Eurofisc network. Fiscalis contributed to implementing two of the Commissions’ 2019 political priorities, demonstrating its continued coherence with the Commissions’ revised political priorities. While the context of the new Commission has changed since the mid-term evaluation, the overall conclusion that it corresponds to the overall political strategy and objective of the Commission remains valid. There also appears to be coherence between Fiscalis 2020 and other similar instruments. Complementarities and synergies exist between the Fiscalis 2020 and the Customs 2020 programme. As established in Article 5 of Regulation (EU) 1294/2013, the general objective of the Customs 2020 Programme is to “support the functioning and the modernisation of the customs union in order to strengthen the internal market […]”. Since DG TAXUD manages both programmes with similar management structures, this achieves efficiency gains in managing the Commission resources. Further, both programmes share many operational features that are co-funded by both programmes and available for customs and tax administrations. The programmes jointly funded key IT infrastructure such as CCN and EU common training materials. This leads to efficiency gains, as it avoids implementing separate systems, and enables customs and tax administrations to exchange information and share knowledge better. The Structural Reform Support Programme (SRSP) 2017-2020 is complementary to Fiscalis 2020. Until 31 December 2019, the Structural Reform Support Service of the Commission managed it, replace by DG REFORM as of 1 January 2020. The SRSP offered tailor-made expertise to all EU Member States to design and implement institutional, administrative and growth-enhancing reforms in different policy areas including revenue (tax and customs) administration. The support ranged from strategic and legal advice, to studies, trainings and expert visits on the ground in any phase of the reform process. The support providers under the SRSP consisted of the European Commission in-house experts, EU Member State public organisations and individual experts, international organisations and private consultancy sector. Regardless of the different objectives, and implementation modalities, synergies exist between both programmes. SRSP complemented Fiscalis 2020 by deploying tailored technical support for the programmes and bringing expertise from external providers such as International Monetary Fund (IMF), World Bank (WB) and Organisation for Economic Co-operation and Development (OECD), private consultancy companies and public organisations. Commission interviewees confirmed that synergies between the SRSP and Fiscalis 2020 exist. In their view, the SRSP could assist a country to undertake more structural reforms to tackle problems discovered during Fiscalis joint actions. For example, Fiscalis 2020 was used to kick-off technical assistance for the Greek tax administration before the launch of SRSP in 2017, which was later continued under Technical Support Instrument (TSI). Complementarities between Fiscalis 2020 and the Hercule III programme managed by the EU Anti-Fraud Office (OLAF) also exist. Article 4 of Regulation 250/2014 laying down the provisions establishing the Hercule III programme indicates that its specific objective is “…to prevent and combat fraud, corruption and any other illegal activities affecting the financial interests of the Union”. Several of the actions eligible for funding under Fiscalis are similar to those under the Hercule III programme. An in-depth analysis and comparison of the Hercule III and Fiscalis’ work programmes revealed no overlap between the two, as the former did not include activities focusing primarily on tax fraud, tax evasion, and aggressive tax planning. On the contrary, one could argue that Hercule III is complementary to Fiscalis, as the fight against fraud conducted with Hercule equipment contributes to the fight against tax fraud and evasion. Despite the complementarities discovered between the programmes, there is no evidence of active cooperation or actively sought synergies. In line with the mid-term evaluation findings, synergies could be further explored through aligning management and planning of the two programmes more closely. Both OLAF and TAXUD receive each other's draft annual work programmes for interservice consultation, as a means to avoid or identify potential overlaps and to seek synergies wherever possible within our respective mandates. The Fiscalis programme also plays a role in and is coherent with programmes for candidate and potential candidate countries. Seven non-EU Member States participated in Fiscalis 2020 via joint actions and training activities. During Commission and Fiscalis coordinator consultations, in three non-EU Member States, aspects of coherence between Fiscalis and other programmes in non-EU Member States were identified. Similar to the Commission’s TSI, the European Commission Technical Assistance and Information Exchange instrument (TAIEX) provides EU neighbourhood country administrations with support for their approximation or accession process to the EU. Through workshops, expert missions or study visits, knowledge and best practices are exchanged between candidate and EU countries, to drive reforms in non-EU Member States. Candidate country interviewees highlighted the benefits of access to both instruments, as Fiscalis is more flexible and provides short-term outcomes, while TAIEX enables non-EU Member States to pursue more long-term reform processes. All non-EU Member States’ representatives emphasised the usefulness of Fiscalis activities in supporting accession negotiations with the EU. They highlighted the importance of its joint actions to gain EU taxation policy framework knowledge and experience, which is important for the accession negotiations. DG NEAR interviewees added the important symbolic value of including non-EU Member States in Fiscalis 2020 as providing an opportunity to establish trust and goodwill between the negotiation parties. 204.2. How did the EU intervention make a difference (value added)? This section reports on what Fiscalis achieved that likely would not have been achieved, at least not as effectively or efficiently, without it. In other words, to what extent is the Fiscalis 2020 programme a vehicle to achieve more than the Member States would do alone? As said, it is difficult to compare Fiscalis 2020 achievements to a counterfactual scenario without it, as its predecessor programmes have been laying the foundation for the achievements for a long time. This aspect is therefore covered from a qualitative, hypothetical point of view. 214.2.1. EU added value of Fiscalis 2020 IT systems Fiscalis 2020 was a fit-for-purpose instrument (see section 4.1). Fiscalis funded IT systems supporting the implementation of legislative changes and harmonisation in rules, to help Member States complying with new legislation. Without it, Member States would have had more difficulties. As discussed, IT infrastructure and systems such as the CCN, DACs, e-Forms, and MOSS made complying more effective and efficient than it likely would have been without an EU-wide coordination mechanism. With EU tax law becoming increasingly important with increasing globalisation and movement of workers (see section 4.3), the programme’s added value is also likely to continue increasing. Relatedly, without cooperation and coordination between Member States, unfair tax competition and tax shopping would likely increase, with fraudsters exploiting the lack of coordination across borders as ‘loopholes’ to avoid taxes. Tax fraud challenges cannot be tackled if Member States do not look beyond the borders of their administrative territories or cooperate intensively with counterparts, e.g. through MLCs, which tax authorities found particularly helpful (see section 4.1.3). It is likely that they would have a degree of bilateral or multilateral cooperation without Fiscalis 2020 and its IT systems. However, such approaches would be much less cost-effective, as this EU-wide approach created economies of scale with interconnected systems and consistent information exchange. Without the CCN system, for instance, Member States would have to link national systems 27 times, and each time potentially with different specifications, implying additional time and financial resource investments and lower security levels when exchanging sensitive data. In sum, without Fiscalis they would need to invest more resources and may have produced weaker results. ·MOSS: As a one-stop-shop allowing businesses to provide VAT returns once rather than in every Member State that they supply e-services, the MOSS provides businesses and Member States significant added value, by efficiently exchanging VAT payment information via one system rather than with 27 Member States bilaterally. It is unlikely that the necessary investments (financial and human resources) would have been made by Member States acting alone to set up a similar system to the MOSS. ·DAC1/DAC2: The Automatic Exchange of Information under DAC1/DAC2 provides significant EU added value by improving efficiency. Without DAC, each Member State would have to develop bilateral arrangements and technical specifications to exchange information, and the frequency and quality of information would likely be worse. ·SEED: Without SEED, relevant information could be not automatically transferred to the EMCS, and tax authorities would likely be exchanging paper-based information, significantly increasing processing times, increasing the potential for human error and inefficiencies. ·TEDB: Without the TEDB, according to interviews with the developers of the Excise Duty Calculator and the Single Digital Gateway, the former would likely not have been developed, and the information on the latter would have been less targeted and of lower quality. By centrally providing information on all major taxes in the EU, it addresses language barrier and other accessibility issues. Another, perhaps unintended added value of the Fiscalis IT systems is that it helped national tax administrations to modernise and digitalise their own internal systems and tools (see section 4.1.2), notably for countries which have more recently acceded to the EU.

224.2.2. EU added value of the Fiscalis 2020 joint actions Joint actions provided considerable EU added value. Expert teams such as those on the Excise Duty Calculator and TNA (Operation teams I and II) were crucial for preparing and implementing the related IT tools. Without Fiscalis financial support for Member States for these initiatives, they likely would not have been developed. The programme generated innovative ideas, developed by experts in Member States, who were largely compensated for their time via grants . Other joint actions such as workshops and seminars involving many actors, but also smaller scale ones like working visits and MLCs, helped tax authorities establish networks across Member States, and facilitated knowledge sharing. Judging from the consistently positive feedback on joint actions’ ability to meet their objectives (see section 4.1), it is safe to assume that they have had a positive impact. Without Fiscalis 2020 funding and (perhaps more importantly) coordination, most likely there would have been fewer events. Tax authorities voiced being faced with limited resources and would not have had the time or money to invest in planning, organising and carrying out such actions without Fiscalis. In fact, the networks and knowledge sharing benefits go far beyond Fiscalis-funded joint action confines. One Fiscalis coordinator explained the networks created through joint actions have also opened up informal cooperation. In their country, there were ongoing tax reforms designed with the help and advice of coordinators from other countries. An interviewee from a non-EU country shared that they hired an Austrian tax expert they met through a collateralised loan obligations (CLO) joint action, as a consultant to help solve internal issues. These connections, especially with non-EU countries, would not have been likely without Fiscalis-funded actions. 234.2.3. EU added value of the Fiscalis 2020 training activities As common training activities are closely related to Fiscalis IT systems, and understanding and implementing taxation Union law, their EU added value lies primarily in how they improved national tax administration officials’ knowledge and capacity and thus the effectiveness and efficiency of administrations. Fiscalis-funded eLearning modules added value beyond the participants as they were also used internally to teach for example. The large number of people trained (e.g. just below 350 thousand, in 2020) is evidence that they were considered useful. These training activities and modules would likely not have been developed if Fiscalis had not been in place. 244.2.4. Likely impact if hypothetically Fiscalis was discontinued Based on the evidence presented, it is fair to say that without Fiscalis we would not have the IT systems, joint actions and training to the extent that we have and that were instrumental in implementing EU taxation law and fighting tax fraud, evasion and aggressive tax planning. While there may have been bilateral or multilateral efforts, they would not have achieved the same level of results as Fiscalis and they would not have benefitted from the economies of scale generated by Fiscalis or the timeline would have been very different and slower. These findings are supported by tax authorities across the board. When asked to imagine a hypothetical situation where the Fiscalis programme was stopped or discontinued, all agreed that it would have significant negative consequences. This includes discontinuing IT systems and joint actions due to a lack of resources. In their view, if Member States continued IT systems themselves, to develop and innovate them would be much slower. Joint actions would also not be possible on this scale if they relied on Member States’ own resources. Existing (bilateral) networks between officials in different countries would continue to be exploited, but not as easily renewed in case of e.g. staff changes. Some interviewees pointed to collaboration with the OECD or the International Organisation of Tax Administrations (IOTA) as an alternative framework. However, they stressed that it would reduce harmonisation and EU-specific benefits such as implementing common EU tax law, because there would not be the crucial IT systems to support it. 254.3. Is the intervention still relevant? This section looks at the Fiscalis programme’s relevance by exploring ‘To what extent does the Fiscalis 2020 continue to respond to tax administrations, businesses and the general public needs. It elaborates the degree to which the Fiscalis 2020 proved and continues to be relevant in achieving its overall aim of improving the proper functioning of taxation systems in the internal market by enhancing participating countries tax authorities’ and officials’, cooperation. It explains the extent to which Fiscalis 2020 was able to tackle new and future challenges and needs stakeholders faced. 264.3.1. Challenges and priorities in the field of taxation The fight against tax fraud, tax evasion and aggressive tax planning is an ongoing challenge that results in significant revenue losses in the EU every year as the VAT gap figures attest. Globalisation and digitalisation combined create new challenges to tax systems ability to collect tax revenue by creating potential for tax avoidance or evasion if tax administrations and systems do not keep up with change. A range of taxation legislative change was adopted during the 2014-2020 period to keep up with the increasingly digitalised, globalised world. Fiscalis 2020 actions were