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
Date: 2022-12-14
Institutions: Directorate-General for Taxation and Customs Union, European Commission
Subjects: EU programme, European tax cooperation, administrative cooperation, exchange of information, fraud, information system, single market, tax authorities, tax law, tax offence

EN 

  EN 

   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 ................................................................................................................................................... 2 

1. 

INTRODUCTION ................................................................................................................................ 4 

1.1.  PURPOSE AND SCOPE OF THE EVALUATION ............................................................................. 4 

2.  WHAT WAS THE EXPECTED OUTCOME OF THE INTERVENTION? ....................................... 5 

2.1.  DESCRIPTION OF THE INTERVENTION AND ITS OBJECTIVES ............................................... 5 

2.2.  POINT(S) OF COMPARISON ............................................................................................................. 6 

3.  HOW HAS THE SITUATION EVOLVED OVER THE EVALUATION PERIOD? ......................... 9 

3.1.  CURRENT STATE OF PLAY ............................................................................................................. 9 

3.2.  FOLLOW-UP  ON  THE  RECOMMENDATIONS  OF  THE  MID-TERM  EVALUATION 

AND RAISING PROGRAMME AWARENESS ............................................................................... 13 

4. 

EVALUATION FINDINGS ............................................................................................................... 17 

4.1.  EFFECTIVENESS  -  TO  WHAT  EXTENT  WAS  THE  INTERVENTION  SUCCESSFUL 

AND WHY? ........................................................................................................................................ 17 

4.1.1. TO WHAT EXTENT HAS FISCALIS 2020 ENABLED THE SECURED EXCHANGE OF 
COOPERATION  AND 

INFORMATION, 
ENHANCED PARTICIPATING COUNTRIES ADMINISTRATIVE CAPACITY? ....................... 17 

SUPPORTED  ADMINISTRATIVE 

4.1.2. TO  WHAT  EXTENT  HAS,  FISCALIS  2020  HELPED  TO  IMPLEMENT  UNION 

TAXATION LAW? ............................................................................................................................ 23 

4.1.3. TO WHAT EXTENT HAS FISCALIS 2020  SUPPORTED THE FIGHT  AGAINST TAX 

FRAUD, EVASION AND AGGRESSIVE TAX PLANNING .......................................................... 26 

4.1.4. TO  WHAT  EXTENT  HAVE  FISCALIS  2020  RESOURCES  PRODUCED  THE  BEST 

POSSIBLE RESULTS AT THE LOWEST POSSIBLE COST? ........................................................ 35 

4.1.4.1.  COSTS  COMPARED  TO  BENEFITS  ASSOCIATED  WITH  FISCALIS  IT 

SYSTEMS ........................................................................................................................................... 37 

4.1.4.2.  COSTS  COMPARED  TO  BENEFITS  ASSOCIATED  WITH  FISCALIS  JOINT 

ACTIONS ........................................................................................................................................... 40 

4.1.4.3.  TRAINING ACTIVITY COSTS COMPARED TO BENEFITS ............................................... 41 

4.1.4.4. 

SCOPE TO MAXIMISE EFFICIENCY ..................................................................................... 42 

4.1.5. TO WHAT EXTENT IS FISCALIS 2020 COHERENT WITH BROADER EU POLICIES ............ 42 

4.2.  HOW DID THE EU INTERVENTION MAKE A DIFFERENCE (VALUE ADDED)? .................. 45 

4.2.1. EU ADDED VALUE OF FISCALIS 2020 IT SYSTEMS ................................................................. 46 

4.2.2. EU ADDED VALUE OF THE FISCALIS 2020 JOINT ACTIONS .................................................. 47 

4.2.3. EU ADDED VALUE OF THE FISCALIS 2020 TRAINING ACTIVITIES ..................................... 47 

4.2.4. LIKELY IMPACT IF HYPOTHETICALLY FISCALIS WAS DISCONTINUED ........................... 48 

4.3.  IS THE INTERVENTION STILL RELEVANT? .............................................................................. 48 

4.3.1. CHALLENGES AND PRIORITIES IN THE FIELD OF TAXATION ............................................. 48 

4.3.2. EXTENT TO WHICH FISCALIS 2020 MET TAX AUTHORITIES’ NEEDS ................................ 49 

4.3.3. EXTENT TO WHICH FISCALIS 2020 MET ECONOMIC OPERATORS’ NEEDS ...................... 51 

 
 
 
 
4.3.4. EXTENT TO WHICH FISCALIS 2020 MET PUBLIC NEEDS ....................................................... 51 

5. 

CONCLUSIONS AND LESSONS LEARNED ................................................................................. 51 

ANNEX I:   PROCEDURAL INFORMATION ........................................................................................... 58 

ANNEX II. METHODOLOGY AND ANALYTICAL MODELS USED IN THE FINAL STUDY .......... 62 

APPROACH ................................................................................................................................................. 62 

EVALUATION QUESTIONS ..................................................................................................................... 62 

OVERALL METHODOLOGICAL FRAMEWORK .................................................................................. 63 

PROGRAMME LEVEL EVALUATION .................................................................................................... 64 

DATA COLLECTION AND ANALYSIS ................................................................................................... 65 

Desk research ....................................................................................................................................... 65 

Stakeholder consultations .................................................................................................................... 65 

Data analysis ........................................................................................................................................ 67 

Case study selection ............................................................................................................................. 67 

TRIANGULATION ..................................................................................................................................... 69 

CONCLUSIONS AND LESSONS LEARNED ........................................................................................... 69 

LIMITS TO THE EVIDENCE BASE AND ROBUSTNESS OF FINDINGS ............................................ 69 

ANNEX III. EVALUATION MATRIX AND, WHERE RELEVANT, DETAILS ON ANSWERS 

TO THE EVALUATION QUESTIONS (BY CRITERION) ............................................................. 71 

ANNEX IV. OVERVIEW OF BENEFITS AND COSTS AND, WHERE RELEVANT, TABLE 

ON SIMPLIFICATION AND BURDEN REDUCTION. .................................................................. 86 

ANNEX V. STAKEHOLDER CONSULTATION – SYNOPSIS REPORT ............................................... 89 

STAKEHOLDER CONSULTATION ACTIVITIES – METHODOLOGY AND APPROACH ................ 89 

INTERVIEWS .............................................................................................................................................. 90 

PROGRAMME LEVEL INTERVIEWS ...................................................................................................... 90 

CASE STUDY CONSULTATION ACTIVITIES ....................................................................................... 92 

PUBLIC CONSULTATION ........................................................................................................................ 95 

CHALLENGES AND MITIGATION STRATEGIES ................................................................................. 97 

KEY FINDINGS PER EVALUATION CRITERIA .................................................................................... 97 

EFFECTIVENESS ....................................................................................................................................... 97 

EFFICIENCY ............................................................................................................................................... 98 

RELEVANCE .............................................................................................................................................. 98 

COHERENCE .............................................................................................................................................. 98 

EU ADDED VALUE ................................................................................................................................... 99 

ANNEX VI. MID-TERM EVALUATION RECOMMENDATIONS ......................................................... 99 

 
 
 
 
 
GLOSSARY 

Acronym 

Definition 

AEOI 
AFF 
ART 
ATP 
CCN 
CLO 
CN 
CPA 
CS 
CSI 
CTA 
DAC 
eAD 
EAF 
EEC 
eFCA 
e-FDT 
EIS 
EMCS 
EU CTS 
EU FATCA 
FPG 
GDP 
IMF 
IOSS 
IOTA 
ITR 
LMS 
MISE 
MLC 
MOSS 
MSC 
MTIC 
OECD 
OLAF 
OSS 
PAOE 

PMF 
SEA 

Automatic Exchange of Information  
Action Follow up Form  
Activity Reporting Tool 
Aggressive tax planning  
Common Communications Network  
Collateralised loan obligations  
Combined Nomenclature 
Classification of Products by Activity 
Central System 
Common Systems Interface  
Conformance Testing Application 
Directive on Administrative Cooperation  
electronic Administrative Document  
Event Assessment Form 
European Economic Community 
e-Forms Central Application 
e-Forms Direct Taxation 
European Information Systems 
Excise Movement Control System  
EU Common Transmission System 
European Foreign Account Tax Compliance Act  
Fiscalis Project Group 
Gross Domestic Product  
International Monetary Fund 
Import One Stop Shop  
International Organisation of Tax Administrations  
Implicit taxation rate 
Learning management system  
Management Information System for Excise 
Multilateral controls 
Mini One Stop Shop 
Member State of consumption  
Missing Trader Intra-Community 
Organisation for Economic Co-operation and Development  
EU Anti-fraud Office  
One Stop Shop  
Presences in administrative offices and participation in administrative 
enquiries 
Performance Measurement Framework 
Single European Act  

 
 
 
System for Exchange of Excise Data   
System for Exchange of Excise Data on Europa website 

SEED 
SEED-on-
Europa 
Structural Reform Support Programme  
SRSP 
Self-Service Testing System 
SSTS 
Staff Working Document 
SWD 
Technical Assistance and Information Exchange Instrument  
TAIEX 
TBE Services  Telecommunications, broadcasting and electronic services 
TEDB 
TFEU 
TIC 
TIN 
TNA 
TSI 
TSS 
VAT 
VIES 
VoW 
WB 

Taxes in Europe Database 
Treaty on the Functioning of the European Union  
Taxation Information and Communication 
Tax Identification Number  
Transaction Network Analysis  
Technical Support Instrument  
Taxation Statistical System 
Value-added tax  
VAT Information Exchange System  
VIES-on-the-web  
World Bank 

 
 
 
1 

1. INTRODUCTION 

This Staff Working Document (SWD) reports on the final evaluation of the Fiscalis 2020 
multiannual  action  programme  (herein  Fiscalis  2020).  The  programme,  running  from 
2014  to  2020,  was  one  of  the  principal  tools  used  to  support  the  implementation  of 
European  Union  taxation  policy.  It  provided  a  framework  with  which  to  improve  the 
proper  functioning  of  the  taxation  systems  in  the  single  market  through  enhanced 
cooperation between participating countries, their tax authorities and officials. It supports 
the implementation of Union law in the field of taxation and the fight against tax fraud, 
tax  evasion  and  aggressive  tax  planning  by  ensuring  the  exchange  of  information, 
supporting  administrative  cooperation  and  enhancing  participating  countries’ 
administrative capacity. 

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  operation  of  taxation  systems  in  the  European  Union.1  In 
compliance  with  Article  17(1)(2)  of  the  Regulation,  the  Commission,  assisted  by 
independent  external  evaluators,  conducted  studies  to  support  final  and  mid-term 
evaluations of the programme. 

2 

1.1.  PURPOSE AND SCOPE OF THE EVALUATION 

As mandated by Article  17(3) of the  Fiscalis 2020 Regulation, the  purpose of the  final 
evaluation is to assess the programme’s performance from 2014 to 20202 and the extent 
to  which  results  achieved  will  be  sustained  in  the  longer  term.  The  scope  of  the 
evaluation  covers  the  programme’s  years  of  operation  (2014-2020).  It  incorporates  the 
mid-term  evaluation  findings  conducted  in  2018  and  assesses  the  degree  to  which 
recommendations  made  then  were  implemented  and  whether  such  follow-up  actions 
brought about improvements. The geographical scope includes all participating countries, 
i.e.  EU  Member  States3,  candidate  countries  (Albania,  North  Macedonia,  Montenegro, 
Serbia  and  Turkey)  and  potential  candidates  (Bosnia  and  Herzegovina  and  Kosovo*). 
The evaluation takes into account the programme’s full range of funded and management 
activities  and  all  the  relevant  stakeholders  (national  administrations,  Commission 

1 Note that Regulation (EU) 2021/847 of the European Parliament and of the Council of 20 May 2021 established the 
ongoing  ‘Fiscalis’  programme  for  cooperation  in  the  field  of  taxation  which  covers  the  period  2021-2027.  The 
Regulation and repeals Regulation (EU) No 1286/2013 that had created the Fiscalis programme evaluated here. 

2  A  number  of  the  2020  Fiscalis  programme  activities  continued  in  2021  as  most  grant  agreements  have  been 
prolonged to 2021.  

3 The United Kingdom withdrew from the EU and is a third country as of 1 February 2020. It was therefore considered 
a participating EU country for most of the programme duration. 

4 

 
 
 
services  and  economic  operators)  from  all  participating  countries  (including  candidate 
and potential candidate countries).  

This evaluation round focused strongly on Fiscalis IT structure and systems (also referred 
to in this report as European Information Systems – EIS) as they account for around three 
quarters  of  the  Fiscalis  2020  budget  and  were  not  previously  evaluated  in-depth.  This 
was  done  through  five  in-depth  case  studies.  See  Annex  II  for  more  on  the  final  study 
methodology including the case study selection. Other Fiscalis-funded activities are also 
evaluated, providing a well-rounded picture of the programme performance as a whole. 
The  final  evaluation  also  draws  on  the  experience  of  its  predecessor  programmes,  as 
Fiscalis  2020  cannot  be  evaluated  without  considering  them.  In  addition,  it  considers 
future evolutions for the programme’s continued relevance and changes foreseen for the 
2021-2027 programming period. 

In  line  with  Article  18(1)  of  Regulation  (EU)  No  1294/2013,  which  mandates  an 
independent  final  evaluation  of  the  programme,  the  Commission  services  (Directorate 
General  for  Taxation  and  Customs  Union  -  DG  TAXUD)  commissioned  an  external 
contractor  to  perform  a  study  in  support  of  the  Commission  evaluation  (hereinafter 
referred  to  as  ‘the  external  study’).  The  external  study  was  carried  out  between 
November  2020  and  January  2022  and  is  a  key  contribution  to  this  staff  working 
document (SWD).   

The evaluation assesses the degree to which the programme achieved its objectives, the 
efficiency  of  resources  used  (including  potential  for  simplification),  the  programme’s 
contributions  to  the  EU  priorities  of  smart,  sustainable  and  inclusive  growth,  the 
continued relevance of its objectives, and its added value at EU level. On that basis, this 
evaluation provides the Commission with overarching conclusions and lessons learned to 
inform the implementation of the recently established successor Fiscalis programme for 
the  2021-2027  period.  The  findings  are  deemed  robust  and  the  conclusions  accurately 
drawn. The staff working document is based on the findings and conclusions presented in 
the supporting external studies (see Annex 1 for organisational details).  

3 

4 

2. WHAT WAS THE EXPECTED OUTCOME OF THE INTERVENTION? 

2.1.  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).  

5 

 
 
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 Committee4. 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.  

5 

2.2.  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  budget5  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’. 

4 Established according to the Comitology rules set up in Regulation (EU) No 182/2011 of the European Parliament 
and  of  the  Council  of  16  February  2011  laying  down  the  rules  and  general  principles  concerning  mechanisms  for 
control by Member States of the Commission’s exercise of implementing powers.  

5 As set out in Article 17 of the Fiscalis 2020 Regulation, the Commission is required to monitor the implementation of 
the programme and its actions. 

6 

 
 
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.   

7 

 
 
Figure 1: Fiscalis 2020 Intervention logic 

8 

 
 
6 

7 

3. HOW HAS THE SITUATION EVOLVED OVER THE EVALUATION PERIOD? 

3.1.  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.6   

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). 

Table 1 : Committed expenses per budgetary year and main programme action categories, in euros 

2014 

2015 

2016 

2017 

2018 

2019 

2020 

23 053 874 

24 691 254 

23 244 421 

24 824 594 

22 375 306 

24 768 693 

25 020 819 

Total 2014-
2020 
167 978 961 

75.6% 

3.1% 
3 902 540 

1.8% 
405 000 

0.18% 
222 085 746 

100 % 

European 
Information 
Systems – 
fiscalis IT 
systems 
Joint actions 
other than 
expert teams 
and studies 
Joint actions 
- studies and 
communicati
on 
Training 

Joint Actions 
- expert 
teams 
External 
experts 

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% 

2 184 539 

1 375 690 

1 640 916 

1 898 800 

1 867 658 

520 372 

350 232  

9 838 207 

908 585 

600 003 

1 205 600 

- 

1 352 000 

1 374 000 

1 483 000 

6 923 188 

4.4% 

- 

- 

988 040 

519 915 

899 585 

330 000 

1 165000 

75 000 

70 000 

70 000 

70 000 

70 000 

- 

50 000 

TOTAL 

30 776 998 

30 966 947 

31 448 977 

31 853 309 

31 477 049 

32 569 465 

32 993 001 

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.  

6  Commission 
Staff  Working  Document: 
SWD_2022_27_1_EN_document_travail_service_part1_v2.pdf (europa.eu)  

Fiscalis 

2020 

Programme 

Progress 

report 

2020 

9 

 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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;  

10 

 
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; 
 public administration capacity-building and supporting actions;  

f. 
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. 

11 

 
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. 

Figure 2: Evolution of participation numbers in joint actions under Fiscalis 2013 and Fiscalis 2020 

Source: DG TAXUD ART data 

 Figure 3: Total instances of participation in joint actions according to action type, 2014-2020 

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. 

12 

 
 
 
 
 Figure 4: Overview of joint action participants per country in 2020  

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.7  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.  

8 

3.2.  FOLLOW-UP  ON  THE  RECOMMENDATIONS  OF  THE  MID-TERM  EVALUATION 
AND RAISING PROGRAMME AWARENESS 

The Fiscalis 2020 mid-term evaluation8 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.  

7 
the 
https://ec.europa.eu/taxation_customs/eu-training/taxcompeu-eu-competency-framework-taxation_en.  As 
Commission  only  launched  capacity-building  actions  for  taxation  in  2020,  the  results  are  not  visible  yet.  Further, 
national support for implementation was offered in 2021. 

8 Mid-term evaluation of the Fiscalis 2020 programme, Executive summary mid-
term_evaluation_summary_report_f2020.pdf (europa.eu).  

13 

 
 
 
 
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.  

Table 2: Mid-term evaluation recommendations by responsibly actor, period and status 
Status 
No.  Recommendation 

Responsible actor 

1  Make  more  practical  use  of  the  Annual 
Work  Programme  projects  and  consider 
multi-annual programming 

DG TAXUD 

Implemented  

DG TAXUD 

Implemented  

Designate  long-term,  platform-like  joint 
actions  as  such,  so  that  appropriate 
criteria  can  be  defined  for  funding 
applications  and  monitoring  of  such 
actions 

Refine  strategy  for  development  and 
promotion of elearning modules 

Investigate  ways 
the 
technological platform for the delivery of 
elearning modules 

improve 

to 

the 

Improve 
the 
translation,  localisation  and  updates  to 
elearning modules 

procedures 

for 

DG TAXUD & 
national 
administrations 

DG TAXUD & 
national 
administrations 

DG TAXUD & 
national 
administrations 

Increase  coordination  with  other  EU 
programmes 

DG TAXUD & 
other DGs 

Optimise  the  procedures  and  resources 
for the implementation of joint actions 

DG TAXUD & 
national 
administrations 

2 

3 

4 

5 

6 

7 

8 

Implemented 

Implemented 

Implemented 

In progress 

Implemented 

Streamline the monitoring system so that 
it  meets  actual  needs  while  reducing 

DG TAXUD 

Implemented 

14 

 
No.  Recommendation 

administrative burdens 

Responsible actor 

Status 

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 

Improve 
sharing tools 

reporting  and 

information-

DG TAXUD 

Implemented  

10 

11 

In progress  

In progress 

Not started 

Increase senior-level buy-in and political 
will 

National 
administrations 

12  Communicate  more  actively  about  the 

possibilities of the programme 

13  Review 

strategy 

for  dealing  with 

economic operators and citizens 

National 
administrations 

DG TAXUD & 
national 
administrations 

15 

 
 
 
 
Table 3: Implementation state of play of the 48 actions identified for the 13 mid-term recommendations 
No.  Recommendation 

Implemented 

Total 
no  of 
actions 

Not 
started 

In 
progress 

Programming and design subtotals  

1  Make  more  practical  use  of  the  Annual 
Work  Programme  projects  and  consider 
multi-annual programming 

13 

4 

0 

0 

12 

3 

1 

but 
1 
not  EU 
level 
action 

2 

3 

4 

5 

Designate  long-term,  platform-like  joint 
actions 

Refine  strategy  for  development  and 
promotion of elearning modules 

Investigate  ways 
the 
technological platform for the delivery of 
elearning modules 

improve 

to 

the 

Improve 
the 
translation,  localisation  and  updates  to 
elearning modules 

procedures 

for 

Implementation subtotals  

6 

7 

8 

9 

Increase  coordination  with  other  EU 
programmes 

Optimise the procedures and resources for 
the implementation of joint actions 

4 

Monitoring and reporting subtotals  

Streamline  the  monitoring  system  so  that 
it  meets  actual  needs  while  reducing 
administrative burdens 

Develop  a  more  coherent  approach  to 
assessing programme performance 

7 

2 

2 

3 

2 

10 

6 

18 

6 

1 

1 
discarded 

0 

3 

3 
postponed 
/ 
for 
evaluation 

10 

Improve 
sharing tools 

reporting 

Communication subtotals  

and 

information-

5 

11 

Increase  senior-level  buy-in  and  political 
will 

7 

2 

4 

0 

12  Communicate  more  actively  about  the 

3 

possibilities of the programme 

13  Review 

strategy 

for  dealing  with 

2 

economic operators and citizens 

2 
postponed 

2 
postponed 

2 

2 

3 

2 

8 

4 

4 

15 

6 

4 

5 

2 

1 

1 

1 

1 

0 

0 

0 

1 

1 

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 

16 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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  administrations9.  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.  

Table 4: Programme Poll baseline, target and outcomes 
Indicator 

Target  Mid 

Baseline  
2011 

2015   

End 
2016  

Mid 
2018 

End 
2019 

Target  audience  awareness  of  the 
programme  
Source: Fiscalis Annual Progress Report 2020 

66% 

>75% 

54% 

59% 

48% 

45% 

9 

4. EVALUATION FINDINGS  

10  4.1.  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. 

11  4.1.1. 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 

9  Note  too  that  the  distribution  of  surveys  within  the  national  administration  is  managed  by  the  national 

coordinator in each Member State.  

17 

 
 
 
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. 

Table 5: EISs that contribute to enhancing administrative capacity 

IT 
structure/ 
system  

CCN/CSI  

eFCA  

EMCS  

TIN  

Link to specific objective  

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.  

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.   

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. 

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 
systems 

1-6 

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. 

18 

 
 
 
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 201410. 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 
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). 

their  systems 

Box 1: Case study examples of Fiscalis EIS frequency of use 
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 %)11.  

10 Note that the messages exchanged are for both Customs and Fiscalis IT systems, as the CCN system provides the 
infrastructure for both programmes.  

11 Both systems became functional in June 2017 and comparisons were therefore based on 2018 data.  

19 

 
 
 
 
Box 2: Case study insights of the MOSS role in enhancing participating countries admin capacity 
MOSS  reduced  economic  operators  and  national  tax  administrations  administrative 
burden  

telecommunications,  broadcasting  and  electronic 

Suppliers  providing 
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 
users12  reported  that  TNA  decreased  the  administrative  burden,  associated  with  the 
previous way of exchanging data, and that they had more time to dedicate to analysis13. 
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 

12  Twenty-six  TNA  users  responded  to  the  question  on  whether  or  not  the  administrative  burden  associated  with 
exchanging data has decreased as a result of the introduction of the TNA. Eleven responded “yes, definitely”; 8 – “yes, 
to some extent”; 7 – “there is no effect” 

13  Seven  respondents  indicated  that  they  had  between  25-50 %  more  time  for  analysis  and  other  actions; 14  – up  to 
25 % more time; 5 stated that there was no change. 

20 

 
 
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 results14.  

14 Source: 2020 Fiscalis Progress Report. Scale: 0: ‘not achieved’, 4: ’fully’. Indicated is the share of action managers 
that replied 4 'fully' or 3 'to large extent') 

21 

 
 
 
Table 6: Events, participants and budget per joint action type to improve administrative capacity  
Action specific 
objective 

Number of participants 

Number 
of events 

Action type 

Enhancing 
administrative 
capacity  

Securing information 
exchange  

Supporting 
administrative 
cooperation 

Capacity building 

Project group 

Seminar 

Working visit 

Workshop 

Subotal 

Multilateral Control 

PAOE 

Project group 

Working visit 

Workshop 

Subtotal 

Administrative 
cooperation 

Multilateral Control 

PAOE 

Project group 

Working visit 

Workshop 

Subtotal 

Total 

66 

166 

1 

229 

33 

495 

25 

3 

268 

23 

8 

327 

1 

261 

168 

91 

69 

41 

631 

1.453 

Actual budget 
(EUR)  

232,688.77 

1,586,070.73 

51,646.54 

482,586.86 

521,180.93 

2,874,173.83 

80,683 

1,902 

1,950,459 

28,621 

190,873 

2,252,538 

12,735 

954,713 

127,888 

715,202 

97,161 

1,377,907 

3,285,605 

119 

2076 

44 

442 

589 

3,270 

127 

10 

2,507 

26 

213 

2,883 

15 

1,456 

245 

1,130 

99 

1,499 

4,444 

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.15 
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  materials16.  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 %.  

15 
the 
https://ec.europa.eu/taxation_customs/eu-training/taxcompeu-eu-competency-framework-taxation_en.  As 
Commission  only  launched  capacity-building  actions  for  taxation  in  2020,  the  results  are  not  visible  yet.  Further, 
national support for implementation was offered in 2021. 

16 eLearning data provided by DG TAXUD 

22 

 
 
 
 
 
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. 

12  4.1.2. 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. 

23 

 
 
 
Table 7: IT systems that support implementation of Union law 

IT system  

CCN/CSI  

Link to specific objective  

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.  

taxation, 
(for  direct 
e-Forms 
VAT, 
recently 
recovery; 
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  

TIN  

MOSS  

DAC 1-6  

TEDB 

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.  

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.  

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. 

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.   

By  providing  information  on  all  major  taxes  in  Member  States,  the  TEDB 
facilitates tax compliance. 

Table 8: Events, participants and budget per joint action type to implement Union law (2014-2020) 
Specific objective 

Action type 

Number of 
events 

Number of 
participants 

Actual 
budget 
(EUR)  

Support implementing 
Union taxation law (in 
general) 

Communication 

Multilateral Control 

Project group 

Seminar 

Working visit 

Workshop 

Subtotal  

Source: ART data on events.  

14 

2 

56 

6 

58 

41 

177 

147 

0 

1,237 

184 

84 

1,494 

3,146 

174,406 

0 

722,154 

281,477 

83,310 

1,214,005 

2,475,353 

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 

24 

 
 
 
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 
improve  understanding  and 
implementing of Union taxation law were largely considered (very) useful and achieving 
their intended result. 

joint  actions 

that  were 

intended 

to 

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 

25 

 
on tax matters. As the EU’s main financial tool for taxation, it is inextricably linked to 
policymaking. 

Box 3: Case study examples on their contribution to implementing Union law 
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.  

13  4.1.3. 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. 

26 

 
Table 9: List of EISs implemented to fight tax fraud, evasion and aggressive tax planning   
IT systems 

Link to specific objective 

(TNA) 

EMCS 

SEED 

VIES  and  Vies 
on the Web 

eForms VAT 

DAC 1-617 

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  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  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 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. 
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. 
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)18 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 

17 DAC - Directive on Administrative Cooperation concerns Directive 2011/16/EU and its amendments (2014/107/EU, 

2015/2376/EU, 2016/811/EU, 2016/2258/EU and 2018/822/EU)  

27 

 
 
 
 
 
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. 

Box 4: Case study insights of selected EIS’ contribution to fighting tax fraud, evasion and aggressive tax 
planning 
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 202019. 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 

19 Data for France was not available for this case study. 

28 

 
 
 
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.  

Table 10: Events, participants and budget per joint action to fight tax fraud, evasion or aggressive tax 
planning (2014-2020)  
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 

Source: ART data on events.  

Totals 

Administrative 
cooperation 

Multilateral 
Control 

PAOE 

Project group 

Working visit 

Workshop 

162 

630 

42 

435 

493 

984 

2,746 

1,030 

596,350 

3,771 

2,316,001 

129 

6,681 

1,734 

10,873 

24,218 

54,541 

5,060,208 

1,643,019 

8,304,344 

17,974,464 

29 

 
 
 
 
Figure 5: Share of submitted proposals to fight tax fraud, evasion and aggressive tax planning in percent 
(2014-2019) 

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 
MLCs20 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  

20 Operational MLCs are MLCs that are ongoing during the time the data was gathered (in 2021) 

30 

 
 
 
 
Figure 6: Number of events for MLCs by Member State (2014-2020) 

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.21 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.  

21 Note that the drop in 2019 is due to the fact that two MLC coordinators reported “0” values because MLCs were still 
ongoing at the time of data collection as explained in the Fiscalis 2020 Programme Progress Report 2019. Without the 
two zero values the average would be higher and more in line with the 2020 value. 

31 

 
 
 
 
Figure 7: Achievement of results, as assessed by MLC coordinators 

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  useful22.  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).  23  This 

22 Twenty-two TNA users responded to “Did you find the training activities useful?” in a case study survey conducted; 
17 responded “yes, definitely”; 4 – “yes, to some extent”; 0 – “no, not at all”; 1 – “I don’t know”. 

23  European  Commission,  DG  TAXUD  (2021)  Taxation  trends  in  the  European  Union  –  Data  for  the  EU  Member 
States, Iceland and Norway, Taxation trends in the European Union - Publications Office of the EU (europa.eu) 

32 

 
 
 
  
 
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  indicator24  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.  

Figure 8: EU27 tax revenue compared to Canada, Japan and USA (% of GDP)  

Source: European Commission, Directorate-General (DG) for Taxation and Customs Union, based on Eurostat and 
OECD data 

24  The  VAT  Gap  is  defined  as  the  difference  between  the  VAT  total  tax  liability  and  the  amount  of  VAT  actually 
collected in the same period. 

33 

 
 
 
Figure 9: Evolution of EU28 VAT Gap 2014-2019 

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 Reports25  

All 11 interviewed Fiscalis EU national coordinators26 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 
revenue  and/or 
producing 
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. 

form  of  additional 

tangible 

results 

tax 

the 

in 

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 

25 
https://op.europa.eu/en/publication-detail/-/publication/bd27de7e-5323-11ec-91ac-01aa75ed71a1/language-
en/format-PDF/source-search & Study and reports on the VAT gap in the EU-28 Member States - Publications Office 
of the EU (europa.eu) 

26 Fourteen, 11 EU Member States and 3 candidate countries national Fiscalis coordinators were interviewed  for the 
evaluation. 

34 

 
 
 
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.  

14  4.1.4. 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 
intended  results.  The 
programme  resources  were  worthwhile 
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.  

in  achieving 

the 

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. 

35 

 
Figure 10. Committed budget per type of activity, in EUR million 

Source: Fiscalis 2020 Annual Progress Report 2020  

Table 11: Committed vs budgeted expenses in EUR - Fiscalis 202027  

European 
Information 
Systems  

Joint  actions  (excl. 
expert 
teams  and 
studies)  

Joint actions (expert 
teams only)  

2014 

2015 

2016 

2017 

2018 

2019 

2020 

23,053,874 

24,691,254 

23,244,421  

24,824,594 

22,375,306 

24,768,693 

25,020,819  

(23,477,000) 

(23,450,000) 

(22,140,000) 

(22,347,000) 

(23,141,000) 

(22,860,000) 

(23,090,000) 

4,555,000 

4,230,000 

4,300,000  

4,540,000  

4,912,500  

5,576,400  

4,923,950  

(4,425,000) 

(4,230,000) 

(4,300,000) 

(4,200,000) 

(4,100,000) 

(6,196,000) 

(5,601,400) 

N/A 

N/A 

988,040 

519,915  

899,585 

330,000 

1,165,000 

(1,500,000) 

(650,000) 

(1,530,000) 

(270,000) 

(2,070,000) 

Common 
activities  

training 

908,585 

600,003 

1,205,600  

028 

1,352,000 

1,374,000 

1,483,000 

(1,000,000) 

(1,025,000) 

(1,237,000) 

(1,242,000) 

(1,352,000) 

(1,374,000) 

(1,483,000) 

-

actions 

Joint 
Studies, 
communication  and 
support  

2,184,539 

1,375,690 

1,640,916 

1,898,800 

1,867,658 

520,372 

350,232  

(1,800,000) 

(2,250,000) 

(2,202,000) 

(3,300,000) 

(1,850,000) 

(1,800,000) 

(698,600) 

Other 
(external experts)  

expenditure 

75,000 

70,000 

70,000 

70,000 

70,000 

0 

50,000 

(75,000) 

(70,000) 

(70,000) 

(70,000) 

(70,000) 

(70,000) 

(50,000) 

Total  

30,776,999 

30,966,948 

31,448,978 

31,853,309 

31,477,049 

32,569,465 

32,993,000  

(30,777,000) 

(31,025,000) 

(31,449,000) 

(31,809,000) 

(32,043,000) 

(32,570,000) 

(32,993,000) 

Source: Fiscalis 2020 programme Progress Report 2020, Annual Work Programmes 2014-2020 

27  Budgeted  expenses  in  brackets  constitute  the  Annual  Work  Programmes  planned  funding;  committed  expenses 
above  refer  to  the  committed  amount  to  be  spent  by  year-end  as  presented  in  the  Annual  Progress  Reports.  For 
example,  the  costs  of  workshops  planned  at  the  beginning  of  the  year  are  budgeted.  If  there  is  a  lower  number  of 
workshops, their costs are committed. Data is from the 2020 Annual Progress Report. 

28 In 2017 progress report, training activities committed amount was as EUR 1,242,000. In the 2020 report, it was 0. 
The table is based on figures reported in 2020 for consistency, given adjustments made over time.  

36 

 
 
 
 
 
15  4.1.4.1.  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.  

Box 5: Examples of Member States’ Fiscalis IT system costs, based on case studies 

  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.  

37 

 
to  billing  software 

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 
logic,  capturing  additional 
transactional  information,  website  changes  and  separate  report  requirements  for  MOSS 
returns29.  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. 

Box 6: Example of costs vs benefits for Member States of specific IT systems, based on case studies  

  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 

29 European Commission, DG TAXUD (2016). VAT aspects of cross-border e-commerce - Options for modernisation: 
Implementation assessment of the 2015 place of supply rules and the Mini-One Stop Shop.  

38 

 
 
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 30 , 
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  worthwhile31.  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.  

16  4.1.4.2.  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.  

30  The  Automatic  Exchange  of  Information  were  estimated  at  on  average  EUR  0.65  million  of  recurring  costs  and 
EUR  3.9  million  development  costs  per  Member  States  during  2015-  by  Commission  Staff  Working  Document 
Evaluation of the Council Directive 2011/16/EU on administrative cooperation in the field of taxation and repealing 
Directive 77/799/EEC 

31  Twenty-four  TNA  users  responded  to  the  question  “Do  you  believe  that  the  investments  and  efforts  put  into  the 
platform have been worth it?”. 21 - replied “yes, definitely”; 3 – “yes, to some extent”; 0 – “no, it’s not worth it”; 0 – 
“I don’t know” 

39 

 
 
 
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.  

Figure 11: Average cost per event and per participant  

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).  

40 

 
 
 
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.  

Box 7: Costs vs benefits of specific joint actions  

  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. 

17  4.1.4.3.  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 technology32. 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.  

32 EU Customs and Tax Training Survey Report 2019.  

41 

 
 
18  4.1.4.4.  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.  

19  4.1.5. 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. 

42 

 
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  economy33. 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 developments34;  

  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) 2017-202035 is complementary to 
Fiscalis  2020.  Until  31  December  2019,  the  Structural  Reform  Support  Service  of  the 

33 Communication from the Commission to the European Parliament and the Council an Action Plan for fair and 
simple Taxation Supporting the Recovery Strategy: 
https://ec.europa.eu/taxation_customs/sites/default/files/2020_tax_package_tax_action_plan_en.pdf  

34 The VAT in the Digital Age includes: Modernising VAT reporting obligations (Action A4 in the Tax Action Plan); 
Addressing  the  challenges  of  the  platform  economy  (Action  A23);  and  Avoiding  the  need  for  multiple  VAT 
registrations  in  the  EU  and  improving  the  functioning  of  the  tool  implemented  to  declare  and  pay  the  VAT  due  for 
distance sales of goods imported from outside the EU (Actions A1 and A5). 

35 The SRSP was inherited by the Technical Support Instrument (TSI) 2021-2027 

43 

 
 
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 

44 

 
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.  

20  4.2.  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. 

21  4.2.1. 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 

45 

 
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. 

Box 8: Specific IT systems’ EU added value  

  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.  

22  4.2.2. 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  grants36.  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 

36 The Grants are usually reimbursements, covering 100 % of travel and hosting costs and 50 % of personnel costs.   

46 

 
 
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.  

23  4.2.3. 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)37 
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.  

24  4.2.4. 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. 

37 DG TAXUD eLearning data 

47 

 
 
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.  

25  4.3.  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. 

26  4.3.1. 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 closely 
linked to these developments. For instance, the 2015 VAT place of supply rule changes 
were  accompanied  by  the  introduction  of  the  MOSS  system  to  facilitate  cross-border 
trade in digital services. The DAC directives were introduced to facilitate the exchange 
of  information  between  tax  administrations,  to  ensure  the  fair  payment  of  taxes  for 
taxpayers  (individual  or  entities)  who  generate  income  in  cross-border  activities. 
Technological advances such as the rise in Artificial Intelligence led to innovations such 
as the TNA. 

Looking  to  the  future,  a  relevant  trend  related  to  all  these  aspects  is  the  rise  in  e-
commerce.  As  part  of  Fiscalis  2020  and  building  on  lessons  from  its  implementation, 
notably the MOSS system, preparatory work was done to introduce OSS and the IOSS, 
which became operational on 1 July 2021.  

Moreover, the ongoing COVID-19 pandemic has brought numerous changes in existing 
working  patterns,  such  as  normalising  remote  work.  Hybrid  remote  working 

48 

 
arrangements seem to be here to stay38 which could potentially lead to an increase in the 
movement of workers across Europe in coming years.  

While  tax  matters  remain  Member  States’  competence,  such  structural  changes 
accentuate the need to reinforce tax administration cooperation and national authorities’ 
administrative  capacities.  In  other  words,  EU  action  to  facilitate  Member  States’ 
communication,  cooperation  and  coordination  for  the  internal  market  effective  and 
efficient  functioning  remains  relevant  in  this  context.  Given  Fiscalis  2020  success  in 
addressing  these  aspects  in  the  past,  the  continuous  improvement  of  IT  systems  and 
providing joint actions and training will continue to be relevant.  

As  discussed  in  the  following  subsection,  there  is  wide  consensus  among  key 
stakeholders  that  the  Fiscalis  2020  is  necessary,  relevant  and  corresponds  to  key 
actors’  needs.  Findings  confirm  that  the  programme  is  engrained  in  the  EU  tax  policy 
landscape  and  is  now  one  of  tax  administrations’  and  economic  operators’  main  work-
tools.  

27  4.3.2. EXTENT TO WHICH FISCALIS 2020 MET TAX AUTHORITIES’ NEEDS  

The evaluation confirms Fiscalis-funded activities relevance in addressing challenges tax 
authorities identified in the mid-term evaluation. 

Firstly, EISs are reported to be highly relevant for tax officials’ daily work, as they are 
the  main  information  exchange  platforms,  which  in  turn  fosters  mutual  assistance  and 
coordination.  In  light  of  the  developments  just  outlined,  national  tax  administrations 
emphasise coordination between EU Member States as important for adequately applying 
EU law and fighting tax fraud and evasion. In this regard, the majority of interviews with 
tax authorities and national coordinators confirmed the relevance of Fiscalis-funded EISs 
in setting up common platforms. They serve as communication platforms through which 
Member States can exchange relevant data to fight tax fraud and evasion and implement 
EU law. 

Training  and  joint  actions  are  also  considered  relevant  to  enhance  administrative 
capacity such as knowledge building and networking. Joint actions, particularly working 
visits  and  project  groups,  were  mentioned  repeatedly  as  highly  relevant.  Through  the 
exchange  of  information  and  good  practices,  Fiscalis  supports  policymaking  and  the 
equal and predictable application of EU law, as tax administrations can work together to 
develop and implement taxation policy. For instance, the Fiscalis tax gap project  group 
(FPG/041),  established  in  2016,  gathered  15  national  experts  from  different  Member 
States  to  pool  knowledge  and  share  experience  of  estimating  tax  gap,  essential  for 

38  McKinsey  Global  Institute  (2020)  What’s  next  for  remote  work:  An  analysis  of  2,000  tasks,  800  jobs,  and  nine 
countries. 

49 

 
 
shedding light on tax evasion and tax fraud. The project group’s work resulted in reports39 
to guide tax gap estimations and enhanced coordination. An interviewee also highlighted 
Fiscalis  role  in  developing  dialogue  spaces  where  EU  tax  officials  responsible  for 
operational tasks, harmonising procedures and audits could exchange good practices and 
guidelines. The TNA also offers another good example of where an identified need and 
idea  were  developed  and  materialised  through  several  project  groups.  Overall,  the 
evidence suggests that the Fiscalis 2020 programme allowed tax administrations to have 
a  space  to  exchange  ideas  with  counterparts  in  other  countries,  identify  needs  and 
develop solutions in a joint manner.    

While  all  interviewees  acknowledged  the  programme’s  relevance,  two  interviewed 
stakeholders  mentioned  a  number  of  gaps  that  could  be  addressed.  For  example,  one 
coordinator mentioned that Fiscalis could support the creation of a database on Member 
States’ legislative developments in the tax field, and that it should be adjusted to better 
cover  emerging  developments  affecting  taxation  such  as  the  new  OSS  and  IOSS 
schemes, virtual currencies, digital solutions to combat fraud, etc. 

Overall,  Fiscalis  2020  is  highly  relevant  to  addresses  tax  administrations’  major 
challenges  and  meet  their  needs.  However,  Fiscalis  coordinators  in  candidate  countries 
pointed out their limited capacity to benefit fully from Fiscalis-funded actions due to its 
EU-oriented nature. This adds to the fact that these countries do not have access to all IT 
systems, which affects their ability to take part in related training components. 

28  4.3.3. EXTENT TO WHICH FISCALIS 2020 MET ECONOMIC OPERATORS’ NEEDS  

Securing  a  level  playing  field  and  ensuring  fair  competition  is  key  for  economic 
operators to perform their activities. Moreover, excessive administrative burden and tax 
compliance  costs  can  prevent  some  businesses  from  carrying  out  economic  activities, 
particularly  across  borders.  For  example,  some  economic  operators,  particularly  SMEs, 
can potentially be discouraged from operating beyond their borders due to different VAT 
compliance  requirements  across  countries.  As  above,  recent  legislative  reforms  were 
established  to  update  and  adapt  VAT  rules  on  cross-border  business-to-consumer  e-
commerce activities.  

In particular, Fiscalis IT systems are especially relevant for economic operators. For 
instance, the MOSS proved to  be very relevant  in alleviating the administrative burden 
on  companies  providing  telecommunications,  broadcasting  and  electronic  services  by 
avoiding  filing  VAT  returns  in  each  country  where  services  are  supplied,  which 
improved  tax  compliance.  The  SEED  facilitated  economic  operators’  activities  by 
simplifying compliance via making information easily available.  

39 The Concept of Tax Gaps – Report on VAT Gap Estimations (2016). FISCALIS Tax Gap Project Group (FPG/041). 
This  report  was  followed  by:  "The  Concept  of  Tax  Gaps  -  Report  II:  Corporate  Income  Tax  Gap  Estimation 
Methodologies (2018) and “The Concept of Tax Gaps – Report III: MTIC fraud gap estimation methodologies” (2018). 

50 

 
 
29  4.3.4. EXTENT TO WHICH FISCALIS 2020 MET PUBLIC NEEDS  

Although  Fiscalis  was  not  designed  explicitly  to  address  citizens’  needs,  one  could 
say it is indirectly relevant to the public. Fighting tax fraud and evasion and ensuring 
tax compliance is a shared concern. As illustrated by the 2016 Eurobarometer survey, 
75 %  of  respondents  reported  a  preference  for  major  EU  intervention  in  fighting 
tax fraud while only 5 % reported that the EU should intervene less. 

This should not be surprising, if EU intervention in fighting fraud is more successful, tax 
revenue  will  increase  (a  trend  observed  in  recent  years).  Moreover,  supporting  tax 
administrations  cooperation  and  strengthening  their  capacities  will  result  in  more 
effective and efficient procedures and potentially reduce citizens’ compliance costs.   

30  5. CONCLUSIONS AND LESSONS LEARNED 

This chapter presents key conclusions and lessons learned based on the findings outlined 
in  the  preceding  chapter.  It  entails  a  discussion  of  the  evaluation  findings  and  the 
potential link between the results achieved and the more long-term impacts. 

Fiscalis  2020  contributed  to  enhancing  tax  authorities’  administrative  capacity 
through  IT  systems,  joint  actions  and  common  training  activities,  harmonising 
approaches, simplifying procedures and lowering administrative burdens.  

Fiscalis 2020 enhanced tax authorities’ administrative capacity through IT systems, 
joint  actions  and  common  training  activities.  Joint  actions  focused  on  sharing 
administrative  guidelines  and  procedures  as  well  as  working  practices.  Participants 
reported a high degree of satisfaction with these actions and considered them useful. On 
average 77  % declared that  an administrative procedure, working practice, or  guideline 
derived  from  Fiscalis  2020  led  to  a  positive  change  in  their  administrations’  working 
practices. More than 130,000 tax officials were trained through Fiscalis common training 
activities.  The  numbers  increased  over  time,  and  participants  reported  a  high  degree  of 
satisfaction with the usefulness of these trainings.  

IT  systems  used  for  information  sharing  also  played  a  role  in  this,  by  reducing 
administrative  burdens.  They  reduced  the  time  and  resources  needed  to  carry  out 
activities  such  as  exchanging  information  or  files;  identifying  taxpayers  or  economic 
operators;  collecting  and  analysing  data.  The  IT  systems  therefore  enabled  efficiency 
gains and the shifting of scarce resources to other important tasks. An example of this is 
the  TNA  -  by  making  use  of  advanced  data  analytics  to  spot  potential  cases  of  fraud, 
TNA reduces the manual work associated with exchanging data and detecting potential 
cases  of  fraud  for  Eurofisc  Liaison  Officials.  Although  they  still  need  to  qualify  and 
follow  up  on  those  potential  cases  and  may  not  have  less  work  than  before,  their 
resources are now more focused on qualified investigations, and the potential to identify 
actual fraud cases in the same amount of time is maximised.  

51 

 
 
Fiscalis  2020  reduced  the  administrative  burden  and  compliance  cost  for  taxpayers 
through its IT systems 

The  main  target  group  for  Fiscalis  is  the  national  tax  administrations  in  the  Member 
States,  and  most  of  the  activities,  and  the  IT  systems,  serve  to  improve  exchange  of 
information  between  the  authorities.  Some  Fiscalis  IT  systems  are  directly  relevant  to 
taxpayers  by  improving  access  to  information  such  as  TEDB,  VIES  and  TIN.  Using 
Fiscalis 2020 funding, the MOSS was developed and implemented to enable businesses 
supplying telecommunications, broadcasting and electronic services to file only one VAT 
return  in  one  Member  State,  rather  than  with  several  different  tax  administrations  in 
different countries. Although they incurred compliance costs initially, those were largely 
outweighed by the benefits from using the system. It has been estimated that the costs for 
businesses using MOSS are about 95 % lower than for businesses not using it (EUR 
2,200  vs.  EUR  41,626  per  business  per  year).  Even  if  this  is  overestimated,  the  cost 
savings are likely significant. The same trend will likely be observed with the new OSS, 
introduced on 1 July 2021. Furthermore, the experienced gained from MOSS have been 
instrumental  to  the  new  OSS,  thus  supporting  the  practical  implementation  of  and 
compliance with the rule change taking place. 

Through IT systems and a variety of joint actions including training, Fiscalis 2020 was 
assessed to have contributed to the improved functioning of the EU internal market by 
supporting the fight again tax fraud, tax evasion and aggressive tax planning.  

Estimating and measuring tax fraud, tax evasion and aggressive tax planning is inherently 
difficult since taxable persons or entities deliberately try to hide the information to avoid 
paying  taxes  due.  Still,  the  research  undertaken  for  the  evaluation  study  showed  that 
several of the key indicators on tax fraud, tax  evasion and aggressive tax planning 
show  signs  of  improvement.  Since  2014,  the  VAT  gap  has  reduced.  The  focus  on 
addressing  offshore  wealth  has  increased  as  can  be  seen  through  the  large  volume  of 
leaked documents (as recently as October 2021 with the leak of the ‘Pandora Papers’). 

These developments are difficult to link directly to actions funded by Fiscalis, but there is 
an indirect link, and the evaluations findings show that Fiscalis contributed towards these 
observed trends as exemplified by the following evaluation findings: 

  The TNA  IT system  supports the identification of potential fraud cases,  making 
use  of  advanced  data-analytics  so  the  process  is  more  efficient  than  manual 
checks.  Initial  estimates  show  that  the  fraudulent  or  suspicious  transactions 
uncovered amounted to EUR 5.3 billion in 2020 and a total of 1814 missing trader 
fraud  cases  were  identified40.  It  is  worth  noting  that  TNA  supports  Eurofisc 
Liaison  Officials  to  detect  potential  cases  of  fraud.  The  collected  evidence 

40 Based on data extracted on 17 February 2021. 

52 

 
 
suggests that TNA enables more potential fraud cases to be identified, which can 
then be subsequently addressed;  

services.  The 

  The  MOSS  facilitated  the  filing  of  VAT  returns  for  businesses  providing 
telecommunications,  broadcasting  and  electronic 
system 
significantly reduced the time and effort required for this, compared to a situation 
in  which  VAT  returns  would  have  to  be  submitted  in  several  Member  States. 
Although difficult to make a direct link, this reduced burden could have increased 
compliance  with  VAT  rules,  thus  reducing  the  incidence  of  tax  evasion  by 
businesses supplying telecommunications, broadcasting and electronic services;  
  Through  the  existence  of  the  DAC  framework,  there  is  more  sharing  of 
information  on  income  declared  and  taxes  paid  across  borders,  making  it  more 
difficult  to  evade  taxes.  The  system  also  acts  to  increase  compliance,  thereby 
preventing tax avoidance. As confirmed during the interviews with tax authorities, 
at  least  two  Member  States  pre-fill  tax  returns  based  on  DAC  information,  thus 
reducing the time needed for taxpayers to complete them and avoiding mistakes in 
filling in tax returns;  
In  addition,  capacity  building  activities  such  as  workshops,  seminars,  trainings 
and  working  visits  which  target  topics  and  activities  aiming  to  prevent  the 
occurrence of fraud and tax evasion through knowledge sharing. 

 

Fiscalis  2020  contributed  to  a  coherent  implementation  of  EU  tax  law  through 
information sharing and knowledge transfer  

Fiscalis  is  a  financial  instrument  that  aids  understanding  and  implementing  EU 
taxation  policy  and  not  a  policy  programme.  Evidence  suggests  that  Fiscalis  2020 
contributed to helping Member States understand and implement rule changes, as well as 
learn  and  share  best  practices  for  harmonisation.  For  instance,  MOSS  was  introduced 
simultaneously  with  the  2015  VAT  place  of  supply  rules  on  telecommunications, 
broadcasting and electronic services. It introduced a system through which tax authorities 
could  share  VAT  information  in  a  coordinated  and  centralised  way,  rather  than 
exchanging  information  bilaterally.  MOSS  thereby  facilitated  and  simplified  the 
implementation of the 2015 rule changes; this would have been less efficient if there was 
no  EU-wide  system  to  do  so.  Another  example  is  the  DACs.  The  DAC  Automatic 
Exchange of Information system relies on the CCN, which is required for Member States 
to be able to fulfil the requirements of the DACs. Without the CCN system, it would be 
challenging for tax authorities to securely and automatically exchange information.   

The IT systems were developed and implemented with Fiscalis 2020 funding (and earlier 
iterations  of  Fiscalis)  and  bring  significant  added  value  for  Member  States.  Without 
Fiscalis,  there  would be  less information  sharing  and knowledge transfer,  and thus  less 
harmonisation  of  rules  and  approaches.  In  that  sense,  Fiscalis  can  be  considered  a  key 
instrument for the implementation of EU tax law. 

Fiscalis  will  likely  continue  to  be  a  relevant  tool  to  enhance  taxation  systems  at  EU 
level and should continue to be funded  

53 

 
Fiscalis  remains  a  relevant  instrument  to  fund  the  development,  implementation 
and  operation  of  IT  systems  in  the  field  of  taxation.  The  operational  Fiscalis  IT 
systems are quite diverse, but all aim at achieving Fiscalis objectives and the case studies 
produced evidence that the  IT  structure and  systems  evaluated contributed to  achieving 
these  objectives.  They  enabled  Member  States  to  communicate  and  coordinate  (CCN, 
DACs,  eForms,  EMCS,  TIC);  reduced  administrative  burdens  and  enhanced  economic 
operators’  tax  compliance  (MOSS,  VIES,  VAT  Return);  helped  to  detect  and  combat 
fraud (TNA); or simply provided information to feed into any or all of the above (TEDB, 
TIN, VoW). 

The  collected  evidence  indicated  that  joint  actions  fostered  tax  authorities’ 
cooperation  and  provided  space  to  exchange  ideas  among  counterparts  if  a  specific 
need  was  identified.  They  created  networks  for  participating  tax  authorities,  enabling 
further coordination and knowledge sharing. Based on the findings, seminars, workshops 
and  project  groups,  bringing  Member  States  together,  were  considered  to  have  been 
useful  because  they  foster  mutual  learning  and  harmonisation  in  the  implementation  of 
legislation. TNA is a good example of an IT system, which was developed and governed 
as a result of the cooperation of dedicated tax officials through a series of project groups. 
MLCs  were  also  useful  for  administrative  cooperation,  particularly  in  fighting  fraud. 
Other actions with a narrower scope, e.g. working visits and PAEOs, allowed participants 
to focus on sharing good practices on specific IT system activities, thus fostering mutual 
learning.  

The evidence suggests that expert teams could play a decisive role in developing new 
IT  systems,  though  they  are  relatively  new  and  relevant  for  a  limited  number  of  EIS. 
TNA and the  Excise Duty Calculator are key  examples of systems  that  might  not  have 
existed  if  Fiscalis  2020  did  not  provide  funding  for  expert  teams.  In  light  of  capacity 
constraints, and the significant time investment for these expert teams, Fiscalis funding is 
crucial,  especially  because  Fiscalis  funds  not  only  costs  directly  associated  with  expert 
team  meetings,  but  also  50 %  of  staff  costs  of  participants  (100%  now  with  the  new 
programme). The expert teams saved tax authorities time and money, and increased 
quality  of  IT  solutions,  stemming  from  working  together  in  a  more  synchronised, 
coordinated and collaborative way. In addition, as participation is voluntary, expert teams 
are  an  example  of  true  engagement  on  the  side  of  authorities.  In  the  end,  all  Member 
States  can  benefit  from  the  outcomes  of  expert  teams,  even  if  they  were  not  involved. 
Considering  the  resource  investment  required,  Member  State  participation  in  expert 
teams  shows  their  commitment  and  solidarity  to  improving  the  taxation  system  for  the 
EU as a whole.  

Lesson learned/recommendation  

In  sum,  Fiscalis  components  are  mutually  reinforcing.  The  IT  systems,  joint  actions  and 
training  activities  each  play  a  role,  in  a  complementary  way,  in  the  achievement  of  Fiscalis 
objectives. The design of the programme is therefore fit-for-purpose and should be maintained.  

54 

 
 
The  resources  invested  into  Fiscalis  2020  and  its  components  were  worthwhile 
considering the achieved results  

EIS traditionally take up the largest share of Fiscalis funding (around 75 % each  year), 
because  they  are  expensive  to  develop  and  operate.  However,  they  can  help  Member 
States  collect  additional  tax  revenue,  which  offsets  the  investments.  In  the  case  of 
MOSS, the VAT revenue collected through the system  grew  at  a much  faster rate than 
the overall VAT revenue growth (+87 % for MOSS compared to +17 % for VAT overall 
between 2015-2019). This is due to the general increase in cross-border B2C supplies of 
telecommunications,  broadcasting  and  electronic  services,  and  all  four  consulted  tax 
authorities reported that the system significantly reduced burdens for them in collecting 
VAT revenue for telecommunications, broadcasting and electronic services compared to 
a  hypothetical  situation  in  which  the  system  had  not  existed.  For  the  DAC1/DAC2,  an 
estimated additional EUR 1.6 million in tax revenue per consulted Member State during 
2020  alone41.  It  is  important  to  note  that  most  of  the  costs  borne  by  the  Fiscalis 
programme in the field of IT consist mainly in interconnecting 27 heterogeneous national 
IT systems via exchanges of messages instead of developing central solutions based on 
data  sharing.  This  architectural  decision  follows  the  agreed  legal  basis  of  the 
corresponding  Taxation  European  Information  Systems.  However,  it  can  lead  to  higher 
costs at EU level while limiting the capability of data processing with a possible impact 
on the cost / benefits ratio. 

Lesson learned/recommendation 

The  findings  indicate  that  the  IT  systems  assessed  in  the  study  are  generating  benefits  which 
outweigh  the  costs,  in  terms  of  simplification,  potential  fraud  detection  and  compliance  with 
taxation law. However, the evidence on costs and benefits is weak, and it could be worthwhile for 
DG TAXUD and Member States to explore ways of better measuring the costs and benefits of the 
investments made. More comprehensive data on costs (investments in IT systems) and benefits 
(tax revenue collected, simplification) could feed into further prioritisation and decision making. 

Joint actions are a relatively small financial investment around 15 % of the Fiscalis 
budget, compared to the EIS. As outlined above, the evidence suggests that they were 
very well received by participants. They enabled knowledge sharing, mutual learning and 
capacity building, which in turn can led to efficiency gains for authorities. The benefits 
clearly  outweigh  the  costs  for  tax  authorities  because  their  participation  is  largely 
covered by the Fiscalis budget. This is not the case for non-EU countries, however. The 
interviews  with  non-EU  participants  highlighted  the  perception  that  their  ability  to 
participate is lacking compared to their financial contribution. They do not have access to 
most of the IT systems as they are designed to share data within the EU, and since many 

41  A  considerable  share  of  the  costs  related  to  development  costs,  were  on-off  costs  while  the  recurring  costs  of 
DAC1/DAC2 are marginal. 

55 

 
 
 
of the joint actions are linked to the IT systems, these are perceived as less relevant for 
non-EU  countries.  However,  participation  may  increase  if  their  awareness  of  activities 
that could be relevant for them to participate in is improved. 

Common  training  activities  made  up  only  around  5  %  of  the  Fiscalis  budget  and  were 
used  by  more  than  1  million  people.  As  mentioned  above,  they  not  only  benefited  tax 
administrations,  but  also  taxpayers.  At  an  average  cost  of  less  than  EUR  5  per  person 
trained,  paired  with  their  perceived  usefulness,  training  activities  can  be  considered 
cost-effective although their actual impact cannot be estimated. 

Lesson learned/recommendation 

It is important to involve the participating non-EU countries in the Fiscalis programme’s 
activities where relevant and appropriate, to make their financial investments worthwhile. 
There are many actions  such as working visits, workshops, PAOEs that can have value 
for  participating  non-EU  countries,  for  instance  through  knowledge  sharing  to  enhance 
their tax administrations’ capacity. One way to do this is to ensure full transparency and 
inviting  them  to  events  in  which  they  can  participate.  DG  TAXUD  has  already  made 
moves to address this in Fiscalis 2021-2027, by ensuring that invitations are sent to non-
EU participating countries, unless otherwise justified.  

Fiscalis 2020 was coherent and consistent with EU priorities and it complements other 
funding  programmes  such  as  Customs  2020  and  the  Structural  Reform  Support 
Programme, though there is scope to improve synergies with Hercule III.  

Fiscalis  2020  was  aligned  and  coherent  to  the  Commission  overall  political 
objectives,  especially  to  the  Europe  2020  strategy.  It  flexibly  adapted  to  changing 
priorities and new legislation, fulfilling its role as a funding programme that supports the 
implementation of EU law on taxation.  

Complementarities  and  synergies  exist  between  the  Fiscalis  2020  and  the  Customs 
2020  programme.  DG  TAXUD  manages  both  programmes  with  similar  management 
structures,  and  the  programmes  share  operational  features  that  are  co-funded  by  both 
programmes and available for customs and tax administrations. This promotes efficiency 
gains  in  managing  resources.  Complementarities  between  the  programmes  are  likely  to 
increase in importance in light of the recent adoption of the VAT eCommerce package. 
Nevertheless, a better discrimination of costs and benefits was seen as beneficial 

Fiscalis  is  also  complementary  to  the  SRSP  now  TSI,  which  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. It complemented Fiscalis 2020 by  deploying tailored technical 
support for the programmes and bringing expertise from external providers such as IMF, 
WB  and  OECD,  private  consultancy  companies  and  public  organisations.  SRSP  could 

56 

 
 
assist  a  country  to  undertake  more  structural  reforms  to  tackle  problems  discovered 
during Fiscalis joint actions.  

Finally, Fiscalis is complementary to the Hercule III programme managed by OLAF, 
as  they  share  certain  objectives.  The  fight  against  fraud  supported  with  Hercule 
equipment contributes to the fight against tax fraud and evasion. However, despite their 
complementarity,  there  seems  to  be  limited  active  cooperation  or  actively  sought 
synergies.  Synergies  could  be  further  explored  through  aligning  management  and 
planning of the two programmes more closely. 

Lesson learned/recommendation 

Synergies  can  create  efficiency  gains  through  knowledge,  experience  and  resource 
sharing. DG TAXUD could explore ways to better coordinate with other services such as 
OLAF, for instance through coordination meetings in preparation of the relevant Annual 
Work Programmes. 

57 

 
 
ANNEX I:   PROCEDURAL INFORMATION 

1.  Lead DG, Decide Planning/Work Programme reference. 

The final (PLAN/2020/8201) and mid-term (PLAN/2017/933) evaluations are non-major 
initiatives  organised  in  accordance  with  Article  17(1)(2)  of  Regulation  (EU)  No 
1286/2013  of  11  December  2013  establishing  a  multiannual  action  programme  Fiscalis 
2020  for  the  period  2014  to  2020  to  improve  the  operation  of  taxation  systems  in  the 
European Union.  

The lead Directorate General for the evaluation was the Directorate General for Taxation 
and Customs Union (DG TAXUD).  

2.  Organisation and timing. 

The  evaluation  was  informed  principally  by  Final  Fiscalis  2020  study  conducted  by  an 
external  contractor  Ramboll.  An  inter-service  steering  group  with  the  following 
Commission services who expressed their wish to participate in the group supported the 
study. However, elements of the mid-term evaluation were incorporated into this report 
also as was considered relevant and appropriate.  

Written procedure only 
DG BUDG 
Budget 
DG CNECT 
Communication Networks, Content and 
Technology 
DG EMPL 
Employment, Social Affairs and Inclusion 

Table 12: Commission services that formed the final study’s ISG 
Meetings and written procedure 
DG AGRI 
Agriculture and Rural Development 
DG ECFIN 
Economic and Financial Affairs x 2 

DG ENV 
Environment 
DG FISMA 
Financial Stability, Financial Services and Capital 
Markets Union 
DG DIGIT 
Informatics x 2 
DG HOME 
Migration and Home Affairs 
DG NEAR 
Neighbourhood Policy and Enlargement Negotiations 
DG SG 
Secretariat-General x 2  
DG REFORM 
Structural Reform Support x 2 
DG TRADE 
Trade 
Legal Service 
OLAF 
European Anti-Fraud Office 
DG JUST  
Justice and Consumers (mid-term evaluation only) 
Notes: x 2 indicates the service was also an ISG member for the mid-term study 

58 

 
 
 
 
 
 
 
 
 
 
 
 
The inter-service steering group for the final evaluation met four times on 18 June and 17 
November in 2020 and 21 January and 8 July in 2021. The last meeting was a validation 
for  Fiscalis  2020  programme  during  which  the  external  consultants  presented  their 
findings,  conclusions  and  recommendations.  These  were  further  on  discussed  with  the 
group,  their  validity  and  credibility  confirmed.  The  mid-term  study  was  also  supported 
by an inter-service steering group that met fives time over the life and finalisation of the 
project. The mid-term evaluation report was published42 as well as an executive summary 
of the mid-term evaluation study43.   

3.  Evidence used together with sources and any issues regarding its quality  

The present  evaluation  SWD is  based on work carried out  by external  consultants. The 
material  informing  this  evaluation  consisted  of  (1)  programming  documentation,  (2) 
previous  studies,  reports  and  evaluations,  and  (3)  the  Performance  Measurement 
Framework (PMF), as detailed in Table 13, which also presents the intended purpose of 
use.  

The  evaluations  gathered  also  primary  data  on  the  programme’s  implementation, 
functioning,  results  and  use  directly  from  the  best-placed  stakeholders:  the  tax 
administrations  of  the  participating  countries  and,  albeit  to  a  smaller  extent,  from 
economic  operators.  Evidence  was  collected  through  targeted  consultations  and  cases 
studies, details of how these were collected are in Annex II 0.  

Finally, the Commission organised a public consultation on the Commission’s spending 
programmes and funds. This public consultation was launched within the context of the 
Commission’s  proposals  for  the  next  generation  of  financial  programmes  for  the  post-
2020  Multiannual  Financial  Framework  (MFF).  The  Fiscalis  2020  programme  was 
included  in  the  public  consultation  on  investment,  research  and  innovation,  SMEs  and 
single  market.  The  findings  of  the  consultation  were  incorporated  into  the  mid-term 
stakeholder  consultation  report.  The  public  consultation  part  is  also  Annex  V  of  this 
report.  

Table 13: Sources of information used for the evaluation of Fiscalis 2020  
Source 

Purpose  

1. Programming documentation 

1.1 Programme Regulation 

Regulation (EU) No 1286/2013  

history 

rationale, 

Underlying 
context 
main features of the programme 
key stakeholders and beneficiaries  

and 

42 See the attached for more details of the Fiscalis 2020 mid-term evaluation SWD (europa.eu) 

43 Mid-term evaluation of the Fiscalis 2020 programme: Executive summary  mid-
term_evaluation_summary_report_f2020.pdf (europa.eu) 

59 

 
 
specific and operational objectives 
headline budget figures 
overview of activities and priorities 

1.2 Annual Work Programmes (AWP) 

Structuring and selection of case studies 

The Fiscalis 2020 AWPs are annexed to each 
yearly financing decision 

priorities in terms of resource allocation 

continuing  relevance  and  policy  issues 
of interest for the programme 

expected  results  and  annually  updated 
goals 

2. Studies, reports and evaluations 

2.1 Annual Progress Reports (APR) 

Published  yearly,  available  for  2014,  2015, 
2016 and 2017 

performance/effectiveness 

intervention logic 
programme 
in terms of outputs and results 
insight  into  how  the  PMF  is  used  and 
reported 
structuring  and 
evaluation case studies 
perceived strengths and areas for further 
development  –  early  warnings  and 
learning within the programme 

topicality 

the 

for 

2.2  Evaluations, 
reports 

impact  assessments  and 

Final evaluation of Fiscalis 2013 

Action  Follow-up  Plan:  Final  Evaluation  of 
Fiscalis 2013 

Impact assessment (IA) for Fiscalis 2020 

Study for ex-ante evaluation for Fiscalis post-
2020  

findings,  conclusions  and 

previous 
recommendations 
background  for  recent  developments  in 
the programme 
ideas for other sources of data:  
ideas for issues to explore / build on 
past and envisaged policy context going 

3. Performance Measurement Framework (PMF) 

PMF  management 

3.1 
documentation 

and 

design 

the 
Background  documentation  detailing 
structuring  of  the  PMF,  considerations  and 
reasoning  which  lead  to  its  instigation,  the 
purpose  of 
tool, 
indicators and their use, etc.  

each  data-collection 

design,  mapping  PMF 

Impetus  and  rationale  for  the  current 
design of PMF 
evaluation 
indicators to evaluation questions 
limits of PMF indicators 
purpose 
indicators 
practicalities of PMF data collection and 
their consequences 

and  design  of  different 

3.2 Activity reporting tool (ART) 

in-depth activity descriptions 

60 

 
 
 
in 

context  of  activities 
motivation and needs 
context  of  activities  in  terms  of  relation 
to other activities and AWP projects 

terms  of 

participant satisfaction 
programme  effectiveness  in  terms  of 
perceived achievement of results 
programme  reach  in  terms  of  spread  of 
results in national administrations  

participant satisfaction 
programme  effectiveness  in  terms  of 
perceived achievement of results 
programme  reach  in  terms  of  spread  of 
results in national administrations 

conducted  every  18  months  (Jul-Sept 
2015 + Jan 2017) 

demand  for  and  reach  of  eLearning 
modules 
satisfaction  and  results  of  eLearning 
modules 
training  and  competency  building  for 
EOs 

Budget allocation for EIS 
development and continued operation of 
EIS 
effectiveness and reach of EIS 
demand  and  use  of  programme  outputs 
by economic operators 

Development  within  overarching  policy 
goals addressed by Fiscalis 2020 

programme  impact  and  effectiveness  in 
terms  of  degree  of  implementation  and 
ratio/level of participants/participation 

programme impact in terms of perceived 
extent 
to  which  results  have  been 
achieved 

Management tool that provides the framework 
for collecting and storing basic data about all 
activities,  with  input  beginning  from  grant 
requests 

3.3 Action Follow-up Form (AFF) 

Form  providing  a  self-reported  rating  of  the 
degree of achievement of expected results, to 
be completed for all activities of the previous 
year 

3.4 Event Assessment Form (EAF) 

Form providing a rating by participants of the 
extent  to  which  their  expectations  were  met 
and  expected  result(s)  achieved,  completed 
three  months  after  the  end  of  an  event  or 
yearly in the case of project groups  

3.5 Programme Poll 

A  questionnaire  that  measures  the  awareness 
and  wider  perceptions  of  the  programmes  in 
terms of networking and dissemination 

3.6 Training activity monitoring 

Training  activities  have  separate  monitoring 
and data collection, which feeds into the PMF 
(eLearning statistics + eLearning survey) 

3.7 IT statistics 

Data  on  results  within  IT  collaboration  and 
implementation  of  common  IT  systems  for 
officials and economic operators 

3.8 Impact indicators 

Indicator data not gathered as part of the PMF 
reporting  tools,  but  collected  from  various 
sources in connection with evaluation reports. 

61 

 
 
2  Use of external expertise 

The Commission carried out  two evaluation studies using external consultants procured 
through  a  framework  contract.  The  Fiscalis  2020  final  evaluation  study,  which  is  the 
main study informing this report was conducted Ramboll Management Consulting44. This 
was signed October 2020 for a period not exceeding 12 months. The mid-term evaluation 
study was commissioned to Oxford Research, Coffey, Economisti Associati and wedoIT, 
with a consortium led by Economisti Associati Srl45 for 13 months.  

ANNEX II. METHODOLOGY AND ANALYTICAL MODELS USED IN THE FINAL STUDY 

APPROACH  

The  final  study  had  an  evaluation  approach  that  consisted  of  assessing  relevance, 
effectiveness, efficiency, coherence and EU added value of the Fiscalis 2020 programme. 
To  ensure  this  assessment’s  robustness,  a  structured  evaluation  approach  was  used, 
relying on an elaborated intervention logic, operationalised evaluation matrix, and a mix 
of  data  collection  and  analytical  methods.  The  overall  approach  included  the  following 
four main tasks: 

  Task 1: Structuring and scoping 

  Task 2: Fieldwork 

  Task 3: Analysis and judgement 

  Task 4: Recommendations 

EVALUATION QUESTIONS  

In line with  the Commission’s Better Regulation Guidelines46, the evaluation criteria of 
relevance, effectiveness, efficiency, coherence and EU added value were covered. They 
were addressed through seven key evaluation questions:  

44 Framework Contract No TAXUD/2019/CC/148 

45 Framework Contract TAXUD/2015/CC/132 

46 European Commission, 2017, Better Regulation Guidelines (SWD (2017) 350).  

62 

 
 
 
To what extent has, the Fiscalis 2020 programme:  

  Contributed to fighting tax fraud, evasion and aggressive tax planning? 

  Helped to implement Union taxation law? 

  Enhanced participating countries’ administrative capacity? 

  Resources produced the best possible results at the lowest possible cost? 

  Responded to tax administrations, businesses and the general public needs? 

  Been coherent with broader EU policies? 

  Been a vehicle to achieve more than the Member States would do on their own? 

These  questions  were  operationalised  and  associated  indicators  and  judgement  criteria 
were  developed,  to  provide  a  framework  for  collecting  data  and  making  evaluative 
judgements (see Annex III).  

OVERALL METHODOLOGICAL FRAMEWORK 

The  methodological  approach  consisted  of  a  theory-based  evaluation,  which  had  two 
streams: one at the level of Fiscalis 2020 as a programme, and the other at the level of 
case studies concerning the specific objectives of the programme. The evaluation made 
use of a contribution analysis to uncover the Fiscalis contribution to the observed results, 
including an assessment of why observed results occurred (or not) and the role played by 
the intervention compared to other internal and external factors.  

The  figure  below  is  a  visualisation  of  the  approach,  which  is  described  in  more  detail 
below. 

63 

 
Figure 12: Methodological approach 

Source: Own elaboration 

PROGRAMME LEVEL EVALUATION  

At  the  programme  level,  we  evaluated  Fiscalis  2020  achievements  as  a  whole  as 
compared  to  its  intervention  logic  (see  Figure  1),  which  outlines  what  it  intended  to 
achieve  and  how.  Although  a  theory-based  evaluation  approach  cannot  assess  causality 
and  attribute  observed  changes  to  actual  activities  or  initiatives,  it  can  nevertheless 
demonstrate  programme  contribution  by  clearly  identifying  logical  linkages  in  what  is 
being  observed.  These  serve  as  the  basis  for  making  plausible  judgements  on  the  level 
and scale of Fiscalis 2020 achievements.  

The  programme-level  evaluation  relied  on  desk  research,  interviews  with  stakeholders 
and the case study results.  

The  evaluation  used  contribution  analysis  to  draw  conclusions  on  the  programme’s 
contribution  to  observed  outcomes.  This  enabled  structuring  the  analysis  around 
information gathered, which helped generate hypotheses. These hypotheses were on the 
links  between  Fiscalis  2020  funded  activities,  the  outputs  they  delivered  (IT  systems, 
joint  actions,  etc.),  and  the  results  and  long-term  impacts  these  have  on  beneficiaries, 
economic operators and society as a whole. The hypotheses were tested against the data 
collected.  Crucially,  it  assessed  potential  alternative  explanations  to  strengthen  the 
evaluation  validity  by  providing  a  sound  analysis  of  how  and  to  what  extent  these 
alternative  explanations  helped  or  inhibited  the  programme’s  ability  to  achieve  its 
outcomes.  

64 

 
 
The programme was split into manageable pieces for which individual theory of change 
models  were  developed,  underlying  assumptions  hypothesised,  and  results  measured. 
This  was  done  through  five  case  studies,  each  concerning  one  Fiscalis-funded  IT  tax 
system. 

DATA COLLECTION AND ANALYSIS 

Desk research  

Programme-level   

As the main aim of this study was to assess how well Fiscalis 2020 performed during the 
2014-2020  period,  the  evaluation’s  starting  point  was  to  assess  its  implementation, 
processes and results using the Performance Management Framework. The study relied 
on the Annual Progress Reports and raw data provided by DG TAXUD. On this basis, a 
comprehensive database of activities and associated outputs (e.g. number of joint actions 
organised,  number  of  IT  system  users,  level  of  awareness  of  the  activities,  etc.)  was 
developed. This enabled comparing results over time and across activities.  

Case studies 

Programme-level  data,  previous  studies  and  IT-specific  documents  (e.g.  vision 
documents, business cases) were used to develop the theory of change for each IT system 
case study. DG TAXUD stakeholders verified these in dedicated meetings.  

Stakeholder consultations  

Programme-level   

Consultations  with  key  stakeholders  aimed  to  quantify  and  explore  existing  evidence 
made largely available through the Performance Management Framework and provided 
additional  qualitative  evidence  to  answer  evaluation  questions.  Notably  tax  authorities, 
who are the main target audience of Fiscalis 2020, were consulted. Commission officials 
as  the  implementers  were  also  consulted.  A  number  of  videoconference  meetings  with 
DG TAXUD’s operational and IT unit staff were held during the inception phase. They 
provided a deeper understanding of the programme and its components, as well as data 
availability  and  case  study  selection  insights.  Additional  interviews  with  Commission 
staff in DG TAXUD and DG NEAR took place during the fieldwork phase to further fill 
gaps  and  validate  findings.  An  overview  of  the  stakeholder  activities  is  presented  in 
Figure 12 below47. 

As  the  mid-term  evaluation  was  finalised  in  late  2018,  to  avoid  consultation  fatigue, 
Fiscalis coordinator interviews were only conducted with Member States that were not in 
the  case  studies.  There  were  14  Fiscalis  coordinator  interviews  asking  high-level 

47 For more information, please see Synopsis report.  

65 

 
 
questions  about  the  functioning  and  usefulness  of  Fiscalis  2020.  This  number  was 
considered appropriate, as national coordinators would likely not have a clear picture of 
programme details but a general view of their key challenges and how and to what extent 
Fiscalis  2020  helped  address  them.  The  Commission’s  Better  Regulation  Guidelines 
require  public  consultations  in  evaluations  however;  as  the  public  know,  little  about 
Fiscalis 2020 there was none.  

Case studies 

The  stakeholder  consultations  were  adapted  to  each  case  study’s  IT  system.  The  case 
studies included in-depth interviews with national tax officials in five Member States and 
DG TAXUD staff working with the systems, as well as other Commission staff (e.g. DG 
GROW in the context of TEDB), as necessary (see Table 14). For the TNA IT system, a 
survey  was  developed  to  reach  a  wider  group  of  TNA  users,  who  were  also  invited  to 
provide additional information in follow-up interviews. For MOSS, SEED and TEDB, 9 
(representatives of) economic operators were interviewed on the IT systems’ usefulness, 
effectiveness and efficiency.  

Table 14 Overview of consultation activities 
Programme 
interviews 

Stakeholder type 

In-depth interviews 

DG TAXUD 

DG NEAR 

Fiscalis national coordinators (AT, BG, HR, CY, 
EL, HU, LV, LT, MT, RO, SK, RS, ME, TK) 

Total 

Number of interviews 

2 

1 

14 

17 

Case study 
consultation 
activities 

Stakeholder type 

No. of interviews/survey 
respondents 

In-depth interviews 

National authorities (DE, IE, SE, NL, IT, BE, FI, 
DK, FR, CZ, EE, LU, AT, BG, CY, PT, PL, SI) 

European business organisation 

EU officials (DG TAXUD, DG GROW) 

Total 

Survey (TNA Case 
study) 

TNA user (national tax officials) 

30 

9 

7 

46 

26 

66 

 
 
Data analysis 

Programme-level   

The programme-data analysis consisted primarily of descriptive statistics for the Fiscalis 
2020  quantitative  performance  data,  qualitative  interviews  coding  analysis48  and  cost-
effectiveness  analysis  to  the  extent  possible  with  the  available  cost  data.  The  analysis 
followed  the  evaluation  matrix  to  structure  and  triangulate  results  from  all  the 
information collected. 

Case studies 

The  theories  of  change  were  developed  based  on  desk  research  and  initial  discussions 
with  DG  TAXUD.  Relevant  sources  of  information  were  analysed  and  used  in  the 
contribution  analyses.  Finally,  stakeholder  consultation  and  desk  research  information 
were  assembled,  analysed,  using  contribution  analyses  and  written  up,  as  case  study 
reports.  The  data  collected  was  mapped,  coded  and  analysed  to  assess  if  and  to  what 
extent they confirmed or discounted hypotheses or assumptions of its underlying theory 
of  change.  The  analysis  was  finalised  by  tracing  the  extent  to  which  causal  pathways 
from Fiscalis 2020 funded activities produced the intended outputs, results and long-term 
impacts.  

Case study selection 

To  select  five  case  study  topics,  we  mapped  out  Fiscalis-funded  IT  systems’  key 
characteristics  such  as  functionality,  users,  objective,  cost  and  baseline  situation.  This 
was informed by DG TAXUD documentation and previous reports and evaluations.    

Based  on  exploratory  discussions  with  DG  TAXUD  programming  and  IT  units,  we 
selected five case study topics. This took into account considerations such as objectives 
and  targeted  users;  development  costs;  and  a  mix  of  ‘older’  and  recently  implemented 
systems. The final selection consisted of the following EIS: 

Table 15: Case study selection – description of the IT systems 
IT system 

Short description 

Transaction Network  The  TNA  is  an  automated  data-mining  tool  using  advanced  data  analytics  and 
algorithms  to  detect  potential  cases  of  cross-border  Missing  Trader  Intra-
Community (MTIC)49 fraud quickly and accurately. They are reported to Eurofisc 

48  Coding  is  a  process  of  identifying  a  passage  in  the  text  (qualitative  data),  searching  and  identifying  concepts  and 
finding relations between them. This process helps organise a large amount of qualitative data to identify key emerging 
themes.  

49 MTIC fraud is the most common type of VAT fraud. It pertains to activities that seek to exploit differences in how 
VAT  is  treated  in  different  EU  Member  States.  A  structure  of  linked  companies  and  individuals  is  created  across 
Member  States  to  abuse  national  and  international  trading  and  revenue-accounting  procedures,  taking  advantage  of 
VAT free trading across Member State borders. VAT is applied only to sales within a Member State at the applicable 
domestic  rate.  In  this  way,  when  goods  are  sold,  VAT  is  charged  to  buyers  without  remitting  the  value  to  the  tax 
authorities. 

67 

 
 
IT system 

Short description 

Analysis (TNA) 

liaison  officials  (ELOs)50  for  further  investigation.  It  aims  to  make  detection  of 
risky  traders  and  administrative  cooperation  easier  and  more  efficient.  Key  users 
are thus ELOs.  

Mini One Stop Shop 
(MOSS) 

System for Exchange 
of Excise data on 
Europa website 
(SEED) 

Directive on 
Administrative 
Cooperation 1 and 2 
(DAC1/2) 

The  MOSS  is  an  IT  system  allowing  businesses  supplying  telecommunications, 
broadcasting and electronic (TBE) services to submit their VAT return just once, 
in  their  registered  Member  State.  These  Member  States  can  then  collect  VAT 
returns  and  payments  and  redistribute  them  to  the  Member  States  where  the 
services  are  consumed  and  the  VAT  due.  The  system  therefore  enables 
administrative  cooperation  and  exchange  of  information  between  Member  State 
tax authorities, and reduces TBE services VAT compliance burden for authorities 
and businesses alike. Key users are businesses supplying TBE services and EU tax 
authorities.  

The  SEED  is  a  core  component  of  the  Excise  Movement  and  Control  System 
(EMCS), an IT system  for  monitoring the  movement of excise  goods under duty 
suspension in the EU. SEED is used to record excise traders who are approved to 
hold, move or receive goods under excise duty suspension, details. It also provides 
tax  authorities  with  up-to-date  copies  of  authorised  economic  operators’ 
characteristics, mandatory to complete validation of e-Ads. This removes the need 
to  cross-consult  information  from  one  authority  to  another  and  enables  formal 
validations.  SEED-on-Europa  is  a  public  online  register  that  traders  can  use  to 
verify their trading partners’ SEED for excise authorisations. Key users are excise 
traders and EU tax authorities.  

income  and  holds  assets.  The 

The  DAC  requires  Member  States  exchange  income  information  on  taxpayers' 
without tax residency in their territory. Under this regime, a tax authority where a 
taxpayer is resident receives and sends information to the tax authority where the 
taxpayer  earns 
is  exchanged 
automatically  once  a  year  with  the  Automatic  Exchange  of  Information  system 
(AEOI). In addition, tax authorities  may request  information from other  Member 
States  in  specific  cases  (such  as  tax  audits)  or  send  spontaneous  information  to 
other Member States (e.g. if suspicious transactions are registered). Under DAC1, 
information on taxpayers' income from employment, pensions, directors' fees, life 
immovable  property  are  exchanged.  Under  DAC2 
insurance  products  or 
information  on  taxpayers'  bank  accounts  and  income  from  financial  services  are 
exchanged. Key users are EU tax authorities.  

information 

Taxes in Europe 
Database (TEDB) 

The  TEDB  is  a  freely  accessible  online  database,  providing  harmonised  and 
comparable information on taxation in all Member States. Member States enter the 
information into the database annually and bi-annually, depending on the type of 
tax. The TEDB is a source of information for the Single Digital Gateway51 and the 
Excise  Duty  Calculator52,  which  is  being  developed.  The  VAT  eCommerce 
package53,  which  makes  online  marketplaces  liable  for  VAT  could  increase 

50 Eurofisc liaison officials (ELOs) are national tax officials who cooperate, exchange information and qualify traders 
as risky based on the information they have. They are part of the Eurofisc network, which aims to enhance Member 
States administrative cooperation to combat organised cross-border VAT fraud focusing on MTIC fraud.  

51 The Single Digital Gateway is a single point of access to information (including taxation), procedures and assistance 
services online for citizens and businesses, developed by DG GROW. 

52 The Excise Duty Calculator is another tool, developed using Fiscalis 2020 funds. The project group are working to 
develop a common EU tool to calculate excise duties in Member States trading excise goods. 

53  The  VAT  eCommerce  package,  implemented  July  2021,  will  insist  marketplaces  be  deemed  VAT  suppliers  when 
they facilitate certain cross-border business-to-customer transactions of third-party sellers. It will make them liable to 

68 

 
 
 
IT system 

Short description 

TEDB’s use, as it recently added an option to find goods and services VAT rates 
using  Combined  Nomenclature  (CN)  and  Classification  of  Products  by  Activity 
(CPA) codes. As it is accessible to all, it targets tax authorities as well as economic 
operators and the public.  

TRIANGULATION 

Drawing on evidence from the case studies and the programme evaluation, answers to the 
evaluation  questions  were  formulated.  By  means  of  triangulation  of  the  information 
collected  through  desk  research,  interviews  and  case  studies,  the  study  aimed  to 
overcome  the  weakness  or  intrinsic  biases  and  problems  that  come  from  single 
method/observer/theory studies. Throughout the triangulation process, we referred to the 
evaluation question matrix for the analysis and judgement of each evaluation question, to 
ensure transparent and robust results. 

CONCLUSIONS AND LESSONS LEARNED  

The  findings  informed  conclusions  and  lessons  learned  about  the  achievements  and 
impact  of  different  Fiscalis  2020  elements.  The  Fiscalis  2020  mid-term  evaluation 
recommendations were also assessed, as presented in section 3.2.  

LIMITS TO THE EVIDENCE BASE AND ROBUSTNESS OF FINDINGS 

The  evidence  base  is  considered  robust,  and  the  generated  findings  valid  and 
consistent. Nevertheless, there are inherent  challenges in  evaluating a programme such 
as Fiscalis, which should be highlighted and taken into account when reading the report. 

First,  Fiscalis  2020  is  the  continuation  of  several  initiatives  to  support  and  increase 
administrative cooperation between Member States’ tax authorities, dating back to 1993. 
To some extent, Fiscalis cooperation has become “engrained” in EU tax authorities and 
its  counterfactual  (i.e.  situation  without  Fiscalis)  is  challenging  to  construct.  This  is 
particularly  true  for  IT  systems  in  place  a  long  time,  such  as  the  CCN/CSI,  VIES  and 
EMCS/SEED, where respondents have difficulty imagining implementing EU legislation 
without EIS support. This is an evaluation challenge but can also be seen as a testimonial 
of Fiscalis’ relevance and EU added value.  

Secondly, quantifying Fiscalis 2020 costs and benefits proved difficult. Some EIS costs 
are  shared  with  the  Customs  2020  programme  and  costs  per  policy  field  or  IT  system 
could not be disentangled and attributed with certainty. The evaluation tried to work with 
estimations with DG TAXUD input. Benefits of fraud detected, or tax revenue generated 
proved difficult to obtain and monetise. This is because it is difficult to link such benefits 

collect, report and remit the VAT. This will require access to goods and services VAT rates. The TEDB could provide 
this service.  

69 

 
 
                                                                                                                                                                            
to Fiscalis 2020 and there is a lack of Member State level information in part due to their 
reluctance to share sensitive information on combatting fraud and tax evasion. 

Finally,  the  evaluation  struggled  to  reach  certain  stakeholders.  Respondents  found  it 
difficult  to  prioritise  information  requests,  which  is  not  surprising,  as  Fiscalis  has  two 
evaluations per cycle, requiring feedback from stakeholders every two to three years and 
potentially leading to consultation fatigue. Efforts to reach economic operators to assess 
Fiscalis  2020  simplifying  effects  were  moderately  successful,  but  still  showed  added 
value where it was possible (in particular for MOSS). 

70 

 
ANNEX III. EVALUATION MATRIX AND, WHERE RELEVANT, DETAILS ON ANSWERS TO THE EVALUATION QUESTIONS (BY CRITERION)  

Evaluation question  

Operational questions  

Indicators  

Judgement criteria  

Effectiveness  

1. To what extent has the 
Fiscalis 2020 programme 
contributed to fighting 
against tax fraud, tax 
evasion and aggressive 
tax planning?  

1.1 To what extent is there tangible 
evidence of (positive) change towards 
this objective?  

Evidence on changes with respect to tax fraud, tax 
evasion and aggressive tax planning over the 
evaluation period 

  Descriptive question 

  Descriptive question 

Main sources of 
evidence   

Desk research 

Stakeholder 
consultation 
(Interviews with EU 
stakeholders) 

Desk research (e.g. 
Mid-term evaluation, 
Monitoring data from 
DG TAXUD’s 
reporting tools and 
annual progress 
reports) 

1.2 What actions/types of actions have 
been implemented to address this 
objective?   

1.3 To what extent were the actions 
successfully implemented as intended? 

  Number of IT systems in research/development 
phase/operation implemented to achieve this 
objective 

  Rate and spread of use of these IT systems  

  Number of joint actions implemented for this 

objective 

  Rate and spread of participation therein  

 

 

Evidence on the extent to which Joint actions/ 
Training activities have been implemented as 
intended and contributed to the intended result  

Stakeholder views on the extent to which Joint 
actions/ Training activities have been 
implemented as intended and contributed to the 
intended result 

71 

  Number, rate and spread of actions and 
activities have improved over time 

 

 

Joint actions/ Training activities have been 
implemented as intended and contributed to 
the intended result  

The majority of stakeholders consulted agree 
that Joint actions/ Training activities have 
been implemented as intended and 

Case studies 
Stakeholder 
consultations 
(Interview with EU 
stakeholders and 
national tax 
authorities) 

Desk research (e.g. 
Mid-term evaluation, 
Monitoring data from 

 
 
 
 
 
 
Evaluation question  

Operational questions  

Indicators  

Judgement criteria  

1.4 To what extent was the mix of 
actions implemented conducive to 
achieving the results? 

1.5 What has been the (relative) role or 
importance of the Fiscalis funded IT 
systems to achieve the objective? 

1.6 To what extent can the observed 
effects be attributed to Fiscalis 2020?  

 

 

 

 

 

Evidence that the mix of actions implemented 
was conducive to achieving the results  

Stakeholder views on the extent to which the mix 
of actions implemented was conducive to 
achieving the results  

Evidence that the IT systems contributed towards 
achieving the objective 

Stakeholder views on the importance of IT 
systems in achieving the objective 

Existence of causal link between the IT 
systems/Joint actions/Training activities and a 
contribution to fighting against tax fraud, tax 
evasion and aggressive tax planning 

contributed to the intended result  

The mix of actions implemented was 
conducive to achieving the results  

The majority of stakeholders consulted agree 
that the mix of actions implemented was 
conducive to achieving the results  

The IT systems contributed towards 
achieving the objective 

The majority of stakeholders consulted agree 
that the IT systems contributed towards 
achieving the objective 

There is a causal link between the IT 
systems/Joint actions/Training activities and 
a contribution to fighting against tax fraud, 
tax evasion and aggressive tax planning 

 

 

 

 

 

1.7 What external factors play a role? 

Evidence of external factors 

Limited evidence of external influencing factors 
explaining the result 

Main sources of 
evidence   
DG TAXUD’s 
reporting tools and 
annual progress 
reports) 

Case studies 
Stakeholder 
consultations 
(Interview with EU 
stakeholders) 
Desk research (e.g. 
Mid-term evaluation, 
Monitoring data from 
DG TAXUD’s 
reporting tools and 
annual progress 
reports) 

Case studies 
Stakeholder 
consultations 
(interview with EU 
stakeholders) 
Desk research (e.g. 
Mid-term evaluation) 

Case studies 
Desk research (e.g. 
Mid-term evaluation) 
Answers to previous 
sub-questions 

Case studies 
Stakeholder 
consultations 
(interviews with EU 
stakeholders and 
national tax 
authorities) 

72 

 
 
Evaluation question  

Operational questions  

Indicators  

Judgement criteria  

2. To what extent has the 
Fiscalis 2020 programme 
helped with the 
implementation of Union 
law in the field of 
taxation? 

2.1 To what extent is there tangible 
evidence of (positive) change towards 
this objective?  

Evidence on changes with respect to the 
implementation of Union law in the EU Member 
States (e.g. number of court cases, compliance issues) 

Descriptive question 

2.2 What actions/types of actions have 
been implemented to address this 
objective?   

2.3 To what extent were the actions 
successfully implemented as intended? 

  Number of IT systems implemented to achieve 

Descriptive question 

this objective  

  Rate and spread of use of these IT systems  

  Number of joint actions implemented for this 

objective 

  Number of relevant training activities  

  Number of recommendations, guidelines and 

other outputs issued  

  Rate and spread of participation therein  

Main sources of 
evidence   
Desk research (e.g. 
Mid-term evaluation) 

Desk research 
Stakeholder 
consultation 
(Interviews with EU 
stakeholders) 

Desk research (e.g. 
Mid-term evaluation, 
Monitoring data from 
DG TAXUD’s 
reporting tools and 
annual progress 
reports) 

 

 

Evidence on the extent to which Joint actions/ 
Training activities have been implemented as 
intended and contributed to the intended result  

Stakeholder views on the extent to which Joint 
actions/ Training activities have been 
implemented as intended and contributed to the 
intended result 

  Action managers’ view on the extent to which JA 
that sought to enhance the understanding and 
implementation of Union law in the field of 
taxation have achieved their intended result(s) 

  Number, rate and spread of actions and 
activities have improved over time 

 

 

Joint actions/ Training activities have been 
implemented as intended and contributed to 
the intended result  

The majority of stakeholders consulted agree 
that Joint actions/ Training activities have 
been implemented as intended and 
contributed to the intended result  

Case studies 
Stakeholder 
consultations 
(Interview with EU 
stakeholders and 
national tax 
authorities) 
Desk research (e.g. 
Mid-term evaluation, 
Monitoring data from 
DG TAXUD’s 
reporting tools and 
annual progress 
reports) 

73 

 
 
 
Evaluation question  

Operational questions  

Indicators  

Judgement criteria  

Main sources of 
evidence   

 

 

 

 

 

 

 

Participants’ views on the extent to which a JA 
that sought to enhance the understanding and 
implementation of Union law in the field of 
taxation has achieved its intended results  

Participants’ views on the extent to which an 
event that sought to enhance the understanding 
and implementation of Union law in the field of 
taxation met their expectations  

Participants’ views on the usefulness of an event 
that sought to enhance the understanding and 
implementation of Union law in the field of 
taxation 

Evidence that the mix of actions implemented 
was conducive to achieving the results  

Stakeholder views on the extent to which the mix 
of actions implemented was conducive to 
achieving the results  

Evidence that the IT systems contributed towards 
achieving the objective 

Stakeholder views on the importance of IT 
systems in achieving the objective 

74 

2.4 To what extent was the mix of 
actions implemented conducive to 
achieving the results? 

2.5 What has been the (relative) role or 
importance of the Fiscalis funded IT 
systems to achieve the objective? 

 

 

 

 

The mix of actions implemented was 
conducive to achieving the results  

The majority of stakeholders consulted agree 
that the mix of actions implemented was 
conducive to achieving the results  

The IT systems contributed towards 
achieving the objective 

The majority of stakeholders consulted agree 
that the IT systems contributed towards 
achieving the objective 

Case studies 
Stakeholder 
consultations 
(Interview with EU 
stakeholders) 
Desk research (e.g. 
Mid-term evaluation, 
Monitoring data from 
DG TAXUD’s 
reporting tools and 
annual progress 
reports) 

Case studies 
Stakeholder 
consultations 
(interview with EU 
stakeholders) 
Desk research (e.g. 
Mid-term evaluation) 

 
 
Evaluation question  

Operational questions  

Indicators  

Judgement criteria  

2.6 To what extent can the observed 
effects be attributed to Fiscalis 2020?  

 

Existence of causal link between the IT 
systems/Joint actions/Training activities and a 
contribution to the implementation of Union law 
in the field of taxation 

 

There is a causal link between the IT 
systems/Joint actions/Training activities and 
a contribution to the implementation of 
Union law in the field of taxation 

2.7 What external factors play a role? 

Evidence of external factors 

Limited evidence of external influencing factors 
explaining the result 

3. To what extent has the 
Fiscalis 2020 programme 
enhanced the 
administrative capacity of 
participating countries? 

3.1 To what extent is there tangible 
evidence of (positive) change towards 
this objective?  

3.2 What actions/types of actions have 
been implemented to address this 
objective?   

Evidence on changes with respect to the 
administrative capacity of participating countries 

Descriptive question 

  Number of IT systems in research 

  Descriptive question 

phase/development phase/in operation to achieve 
this objective  

  Rate and spread of use of these IT systems  

  Number of joint actions that sought to extend 
working practices and/or administrative 
procedures/ guidelines in a given area to other 
participating countries implemented  

  Number of training activities implemented for 

this objective 

75 

Main sources of 
evidence   

Case studies 
Desk research (e.g. 
Mid-term evaluation) 
Answer to previous 
sub-questions 

Case studies 
Stakeholder 
consultations 
(interviews with EU 
stakeholders and 
national tax 
authorities) 
Desk research (e.g. 
Mid-term evaluation) 

Desk research 
Stakeholder 
consultation 
(Interviews with EU 
stakeholders) 

Desk research (e.g. 
Mid-term evaluation, 
Monitoring data from 
DG TAXUD’s 
reporting tools and 
annual progress 
reports) 

 
 
 
Evaluation question  

Operational questions  

Indicators  

Judgement criteria  

Main sources of 
evidence   

  Rate and spread of participation therein  

  Number of IT training sessions organised for 

given systems 

  Number of tax officials trained in IT systems/by 

using EU common training material 

  Number of recommendations, guidelines and 

other outputs issued  

  Number of best practices / administrative 

procedures developed/shared 

  Number of face-to-face meetings (total for the 

programme) 

  Number of on-line collaboration groups (PICS) 

(total for the platform) 

  Number of downloaded and uploaded files from 

PICS (total for the platform) 

  Number of tax officials trained in IT systems/by 

using EU common training material 

  Number of EU eLearning modules 
produced/used/downloaded 

 

Total number of operational MLCs  

  Number of Member States participating in MLCs  

  Number of Member States initiating MLCs 

  Number of presences in the offices and 
participation in administrative enquiries 

  Availability of CCN (% of time) 

76 

 
Evaluation question  

Operational questions  

Indicators  

Judgement criteria  

Main sources of 
evidence   

3.3 To what extent were the actions 
successfully implemented as intended? 

  Availability of VIES-on-the-Web (% of time)   

  Availability of EMCS (% of time) 

  Volume of data exchanged on CCN (Customs 

and Taxation) 

  Number of messages on CCN Network (Customs 

and Taxation) 

  Number of European Information Systems  in 
operation, as per Annex 1 of the Fiscalis 2020 
Regulation 

  Action managers’ view on the extent to which 

JAs that sought to enhance collaboration between 
participating countries, their administrations and 
officials in the field of taxation have achieved 
their intended result(s) 

 

Extent to which the target audience is aware of 
the programme 

  Degree of networking generated by programme 

activities 

 

 

 

Extent to which programme outputs (e.g. 
guidelines or training material) are shared within 
national administrations 

Percentage of tax officials who found that the IT 
training met their expectations  

Percentage of tax officials who found the IT 
training to be useful  

  Number of EU eLearning modules produced 

77 

  Number, rate and spread of actions and 
activities have improved over time 

 

 

Joint actions/ Training activities have been 
implemented as intended and contributed to 
the intended result  

The majority of stakeholders consulted agree 
that Joint actions/ Training activities have 
been implemented as intended and 
contributed to the intended result  

Case studies 
Stakeholder 
consultations 
(Interview with EU 
stakeholders and 
national tax 
authorities) 
Desk research (e.g. 
Mid-term evaluation, 
Monitoring data from 
DG TAXUD’s 
reporting tools and 
annual progress 
reports) 

 
 
 
Evaluation question  

Operational questions  

Indicators  

Judgement criteria  

Main sources of 
evidence   

  Number of EU eLearning modules used by 

participating countries (combined number of all 
modules used in each country) 

  Number of tax officials trained by using EU 

common training material 

  Number of times publicly available EU 

eLearning modules were downloaded from 
Europa.eu website   

  Average training quality score by tax officials 

  Action managers’ view on the extent to which 
JAs that sought to enhance administrative 
cooperation have achieved their intended result(s) 

 

 

 

Participants’ views on the extent to which a JA 
that sought to enhance administrative cooperation 
has achieved its intended results 

Participants’ views on the extent to which an 
event that sought to enhance administrative 
cooperation met their expectations  

Participants’ views on the usefulness of an event 
that sought to enhance administrative cooperation 

  Action managers’ view on the extent to which 

JAs that sought to extend working practices 
and/or administrative procedures/guidelines in a 
given area to other participating countries have 
achieved their result(s) 

 

Participants’ views on the extent to which a JA 
that sought to extend working practices and/or 
administrative procedures/guidelines in a given 

78 

 
Evaluation question  

Operational questions  

Indicators  

Judgement criteria  

Main sources of 
evidence   

 

 

 

 

area to other participating countries (has) 
achieved its intended result(s)  

Participants’ views on the extent to which an 
event that sought to extend working practices 
and/or administrative procedures/guidelines in a 
given area to other participating countries met 
their expectations  

Participants’ views on the usefulness of an event 
that sought to extend working practices and/or 
administrative procedures/guidelines in a given 
area to other participating countries 

Percentage of participants that disseminated a 
working practice/administrative 
procedure/guideline developed/shared with the 
support of the programme in their national 
administration (under this objective) 

Percentage of participants which declare that an 
administrative procedure/working 
practice/guideline developed/shared under the 
programme led to a change in their national 
administration’s working practices (under this 
objective) 

  Action managers’ view on the extent to which 

JAs that sought to contribute to the availability, 
reliability and/or quality of (specific) Union 
components of EIS have achieved their intended 
result(s) 

 

Participants’ views on the extent to which a JA 
that sought to contribute to the availability, 

79 

 
Evaluation question  

Operational questions  

Indicators  

Judgement criteria  

Main sources of 
evidence   

 

 

 

 

 

 

 

reliability and/or quality of (specific) Union 
components of EIS (has) achieved its intended 
result(s)  

Participants’ views on the extent to which an 
event that sought to contribute to the availability, 
reliability and/or quality of (specific) Union 
components of EIS met their expectations  

Participants’ views on the usefulness of an event 
that sought to contribute to the availability, 
reliability and/or quality of (specific) Union 
components of EIS 

Evidence that the mix of actions implemented 
was conducive to achieving the results  

Stakeholder views on the extent to which the mix 
of actions implemented was conducive to 
achieving the results  

Evidence that the IT systems contributed towards 
achieving the objective 

Stakeholder views on the importance of IT 
systems in achieving the objective 

Existence of causal link between the IT 
systems/Joint actions/Training activities and a 

80 

3.4 To what extent was the mix of 
actions implemented conducive to 
achieving the results? 

3.5 What has been the (relative) role or 
importance of the Fiscalis funded IT 
systems to achieve the objective? 

3.6 To what extent can the observed 
effects be attributed to Fiscalis 2020?  

 

 

 

 

 

The mix of actions implemented was 
conducive to achieving the results  

The majority of stakeholders consulted agree 
that the mix of actions implemented was 
conducive to achieving the results  

The IT systems contributed towards 
achieving the objective 

The majority of stakeholders consulted agree 
that IT systems contributed towards 
achieving the objective 

There is a causal link between the IT 
systems/Joint actions/Training activities and 

Case studies 
Stakeholder 
consultations 
(Interview with EU 
stakeholders) 
Desk research (e.g. 
Mid-term evaluation, 
Monitoring data from 
DG TAXUD’s 
reporting tools and 
annual progress 
reports) 

Case studies 
Stakeholder 
consultations 
(interview with EU 
stakeholders) 
Desk research (e.g. 
Mid-term evaluation) 

Case studies 
Desk research (e.g. 

 
 
Evaluation question  

Operational questions  

Indicators  

Judgement criteria  

contribution to enhancing administrative capacity 
of participating countries 

a contribution to enhancing administrative 
capacity of participating countries 

3.7 What external factors play a role? 

Evidence of external factors 

Limited evidence of external influencing factors 
explaining the result 

Efficiency  

4. To what extent have 
the Fiscalis 2020 
programme’s resources 
produced best possible 
results at the lowest 
possible cost? 

4.1 What has been the allocation of 
resources for IT systems (and other 
actions) towards the different specific 
objectives? 

4.2 What have been the costs of the 
different IT systems developed / 
maintained through funding from 
Fiscalis 2020, for the EC and for 
Member States? 

  Costs associated with IT systems/Joint 

Actions/Training activities with respect to the 
fight against tax fraud, tax evasion, aggressive 
tax planning 

  Costs associated with IT systems/Joint 

Actions/Training activities with respect to the 
implementation of Union law in the field of 
taxation 

  Costs associated with IT systems/Joint 

Actions/Training activities with respect to 
enhancing the administrative capacity of 
participating countries  

  Cost of Fiscalis IT systems for EU Commission 

  Cost of Fiscalis IT systems for tax authorities 

- 

- 

81 

Main sources of 
evidence   
Mid-term evaluation) 

Case studies 
Stakeholder 
consultations 
(interviews with EU 
stakeholders and 
national tax 
authorities) 
Desk research (e.g. 
Mid-term evaluation) 

Cost data provided 
by DG TAXUD 

Cost data from DG 
TAXUD 
Cost data gathered 
via the case studies 

 
Evaluation question  

Operational questions  

Indicators  

Judgement criteria  

4.3 To what extent are the costs for the 
IT systems justified by tangible 
benefits (cost-benefit of use, 
simplification, achieving specific 
objectives)? 

4.4 To what extent and how could 
efficiency have been improved by 
reducing resources spent, more 
effective or better implementation or 
increasing benefits?   

 

 

 

 

 

Evidence that costs incurred are proportionate to 
the benefits of using Fiscalis IT systems for all 
stakeholders (i.e. achievement of specific 
objectives, simplification) 

Stakeholder views on the proportionality of the 
costs incurred and the identified benefits of using 
the IT systems 

 

 

 

The costs are proportionate to the results 
achieved 

The majority of stakeholders consulted agree 
that the costs were necessary 

The majority of stakeholders consulted agree 
that the costs were proportionate to the 
results achieved 

Stakeholder views on the necessity of the costs 
incurred 

Evidence of inefficiencies or potential ways to 
reduce costs / maximise benefits 

Stakeholder views on potential 
inefficiencies/ways to reduce costs and maximise 
benefits 

There are no inefficiencies identified with respect 
to the costs associated with the programme 

5.1 What are the (new) challenges 
faced by  

 

Identified relevant challenges and needs of each 
stakeholder group  

  Descriptive answer - identified relevant 

challenges and needs of each stakeholder 
group 

Relevance  

5. To what extent does 
the Fiscalis 2020 
programme continue to 
respond to the needs of 
the tax administrations, 
businesses and the 
general public? 

a)  the national tax 
administrations,  
b)  economic operators,  
c)  the general public? 

5.2 Are these (new) challenges 
appropriately addressed by Fiscalis 
2020? 

 

Evidence of the Fiscalis 2020 Joint actions / 
Training activities / the European Information 
Systems matching the identified needs  

 

The majority of consulted stakeholders 
within each group agree that Fiscalis 2020, 
including its objectives and funded actions / 

82 

Main sources of 
evidence   

Answers to questions 
on Effectiveness 
Answers to the 
previous questions on 
Efficiency 
Stakeholder 
consultations 
(interviews with EU 
stakeholders and 
national tax 
authorities) 
Case studies 
Desk research (e.g. 
Mid-term evaluation) 

Stakeholder 
consultations 
(Interviews with EU 
stakeholders and 
national tax 
authorities) 
Case studies 
Desk research (e.g. 
Mid-term evaluation) 

Stakeholder 
consultation 
(Interviews with 
national authorities 
and EU stakeholders) 
Desk research 
Case studies 

Stakeholder 
consultation 
(Interviews with 
national authorities 

 
 
 
 
Evaluation question  

Operational questions  

Indicators  

Judgement criteria  

activities, was relevant  

 

The programme was sufficiently flexible to 
address new challenges and needs 

 

Stakeholder views on the extent to which Fiscalis 
2020 meets their needs  

o  Views on extent to which JA events 

(related to each of the objectives) met 
their expectations 

o  Views on usefulness of JA events 

o  Views on extent to which training 
activities (related to each of the 
objectives) met their expectations 

o  Views on usefulness of training 

activities 

o  Views on extent to which the EIS met 

their expectations 

o  Views on usefulness of the EIS 

  Gaps identified by stakeholders that are not 

addressed by Fiscalis 2020  

Main sources of 
evidence   
and EU stakeholders) 
Desk research 
Case studies 

Coherence  

6. To what extent is the 
Fiscalis 2020 programme 
coherent with broader EU 
policies? 

6.1 To what extent is Fiscalis 2020 
coherent with the new Commission’s 
strategic priorities? 

 

 

 

Identified main differences between Commission 
priorities in 2013 and those in 2019/2020 (given 
the fact that some of the long-term strategies and 
priorities have changed) 

  Descriptive answers providing concrete 

examples of ways in which Fiscalis 2020 
contributes to the priorities of the 
Commission 

Identified ways in which Fiscalis 2020 
contributes to the new priorities of the 
Commission 

  No evidence of inconsistencies between 

Fiscalis 2020 and the new strategic priorities 
of the Commission 

Evidence of inconsistencies between Fiscalis 
2020 and the new strategic priorities of the 

 

Fiscalis 2020 is coherent with the new 
strategic priorities of the Commission 

Desk research (e.g. 
Mid-term evaluation) 
Stakeholder 
consultations 
(Interviews with EU 
stakeholders) 

83 

 
 
Evaluation question  

Operational questions  

Indicators  

Judgement criteria  

Main sources of 
evidence   

6.2 To what extent is the programme 
complement/reinforce other similar 
instruments? (e.g. Customs 2020, 
Hercule III, Structural Reform Support 
Programme) 

 

 

 

Commission 

Evidence of coherence between Fiscalis 2020 and 
the new strategic priorities of the Commission 

Evidence of complementarity between Fiscalis 
and related instruments, such as Customs 2020, 
Hercule III, the newly adopted Tax Package 

Evidence of inconsistencies and gaps between 
Fiscalis 2020 and the new strategic priorities of 
the Commission 

(especially, with respect to the EU priority of 
smart, sustainable and inclusive growth) 

  No evidence of inconsistencies and gaps 
between Fiscalis 2020 and related 
instruments, such as Customs 2020, Hercule 
III, the newly adopted Tax Package  

 

Evidence that Fiscalis 2020 and other related 
instruments complement and reinforce each 
other in terms of objectives first and followed 
by activities 

Desk research 
(legislative and 
strategic planning 
documents) 
Stakeholder 
consultation 
(Interviews with EU 
stakeholders) 

7.1 What do key stakeholders perceive 
as the main EU added value of the 
Fiscalis 2020? 

 

EU added value identified by stakeholders  

  Descriptive question to form a hypothesis on 
what constitutes the EU added value of 
Fiscalis according to stakeholders 

7.2 To what extent does the evidence 
collected in the evaluation support 
these perceptions of added value? 

 

Evidence of EU added value stemming from the 
preceding evaluation criteria with respect to: 

 

o  Reducing administrative burden and 

costs and improving the capacity of tax 
authorities 

Fiscalis 2020 has considerable EU added 
value according to stakeholders with respect 
to: 

o  Reducing administrative burden 

and costs 

Stakeholder 
consultation 
(Interviews with 
national authorities 
and EU stakeholders) 

Evidence from 
preceding evaluation 
questions 
Desk research (e.g. 
Mid-term evaluation 
results) 
Case studies 

EU added value  

7. To what extent is the 
Fiscalis 2020 programme 
a vehicle to achieve more 
than the Member States 
would do alone? 

o  The exchange and storage of 

o  The exchange of information 

information between tax authorities and 
with economic operators 

o  Administrative cooperation  

between authorities 

o  Administrative cooperation 

o  Other aspects identified in the 

o  Other aspects identified in the 

evaluation 

84 

 
 
Evaluation question  

Operational questions  

Indicators  

Judgement criteria  

evaluation 

7.3 To what extent could Member 
States have achieved the same results 
without the support of Fiscalis 2020? 

7.4 To what extent has Fiscalis 2020 
complemented the activities and 
policies of the Member States?  

 

 

Stakeholder views on the likelihood that the same 
results could be achieved by Member States 
acting alone or together 

Evidence on the complementarity between 
Fiscalis 2020 and national activities and policies 
of Member States 

 

Stakeholder views on the complementarity  

7.5 What would happen if the Fiscalis 
programme were discontinued? In 
particular, how would the existing IT 
systems be managed and maintained? 
What would be the effect of 
discontinuing Joint Actions and 
training activities? 

 

 

Stakeholder assessment of likely sustainability of 
the programme’s results should the programme 
be discontinued in terms of management and 
maintenance of IT systems 

Stakeholder assessment of the potential effect of 
discontinuing:  

 

 

 

The majority of consulted stakeholders agree 
that Fiscalis 2020 goes beyond what they 
could achieve bilaterally or multilaterally by 
the activities and policies of Member States  

There are synergies between Fiscalis 2020 
and activities and national policies of 
Member States 

The majority of consulted stakeholders agree 
that Fiscalis 2020 complements activities and 
national policies of Member States  

  Descriptive question 

Main sources of 
evidence   

Stakeholder 
consultation 
(Interviews with 
national authorities 
and EU stakeholders) 

Stakeholder 
consultation 
(Interviews with 
national authorities) 
Case studies 
Desk research 
Answer to Question 6 

Stakeholder 
consultation 
(Interviews with 
national authorities 
and EU stakeholders) 

o 

Joint Actions 

o  Training activities 

85 

 
 
ANNEX IV. OVERVIEW OF BENEFITS AND COSTS  

86 

 
 
 
 
 
Citizens/Consumers  

Businesses 

Administrations 

Quantita
tive  

1. NA 

2. NA 

3. NA 

Direct Costs: 

1. IT capacity 
building 
(EIS supported by 
fiscalis) 

2. Joint Actions 

3. Training 

Comment  Quantitati

Comment 

Quantitative 

Comment  

There are no 
direct costs 
for citizens 
consumers. 

ve  

1. NA 

2. NA 

3. NA 

There are no 
direct costs 
for 
Businesses. 
Of course 
these have to 
learn how to 
work and 
adjust to new 
IT systems. 
So they can 
incur indirect 
costs for EIS, 
for example 
associated 
with required 
changes to 
billing 
software 
logic, 
capturing 
additional 
transactional 
information, 
website 
changes.  

Member States 
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 was 
difficult to 
accurately 
estimate the costs 
associated with 
this aspect of 
participating in 
the Fiscalis 2020 
programme, and 
interviewed 
coordinators 
were unable to 
provide 
estimates. Some 
joint actions also 
involved some 
costs for hosting 
countries. 

1. Not all costs have 
been identified. 
However, based on a 
sample of case 
studies the EIS 
related costs were: 
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; 
DACs related costs: 
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: are around 
2.6 FTE a year on 
average. 

2. The majority of the 
costs associated with 
participation in 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 
and these mostly 

87 

 
 
                        
 
 
 
 
 
regard country visits 
where Fiscalis covers 
travel and subsistence 
but organisation costs 
are borne by the host 
countries.  
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). 

3. NA 

Direct benefits  

1. Based on a sample 
of case studies the 
EIS related benefits 
included: 

DAC1/ DAC2: EUR 
0.5 million net a year 
in additional tax 
revenues;  

TNA: for every EUR 
1 spent, EUR 1,454 
of fraudulent or 
suspicious 
transactions detected 
leading to estimates 
assess of EUR 5.3 
billion worth of 
fraudulent or 
suspicious transaction 
detected; 

SEED time savings 
(not possible to 
quantify);  

TEDB: considered 
cost-efficient in the 
provision of 
information. The EIS 
increased 
interoperability and 
information sharing 
among authorities.  

Many of the 
benefits are 
inherently 
difficult to 
quantify. 
Nevertheless, the 
evaluation 
revealed concrete 
examples of 
benefits 
outweighing 
costs. 

In general, the 
evaluation has 
also assessed that 
the programme 
has contributed 
to a better 
application of 
Union law in the 
field of taxation 
and effective in 
supporting the 
fight against tax 
fraud, evasion 
and ATP. 

88 

Direct Benefits: 

1. IT capacity 
building (EIS 
supported by 
fiscalis) 

2. Joint Actions 

3. Training 

Indirect Benefits: 

1. IT capacity 
building (EIS 
supported by 
fiscalis) 

2. Joint Actions 

3. Training 

Direct 
benefits 

1.NA 

2.NA 

3.NA 

Indirect 
benefits 

1./2./3. 
Higher 
complia
nce and 
less tax 
evasion 
and 
avoidanc
e can 
benefit 
the 
general 
public in 
an 
indirect 
manner. 

The 
programme 
was not 
designed 
explicitly to 
address 
citizens/consu
mers’ needs. 
One could 
say it is 
indirectly 
relevant to 
the public as 
tax 
compliance 
and fighting 
tax fraud and 
evasion and 
ensuring tax 
compliance is 
a shared 
concern. In 
that sense one 
could say that 
any 
improvement
s in this area 
that the 
programme 
may have 
supported 
have a very 
general 
indirect 
benefit to the 

Direct 
benefits  

1.Based 
on a 
sample of 
case 
studies 
the EIS 
related 
benefits 
included 
important 
savings: 
the costs 
of using 
MOSS 
are about 
95 % 
lower 
than costs 
for 
businesse
s not 
using it 
(EUR 
2,200 vs. 
EUR 
41,626 
per 
business 
per year); 
TEDB: 
considere
d cost-

Many of the 
benefits are 
inherently 
difficult to 
quantify. 
Nevertheless, 
the case 
studies 
conducted as 
part of this 
evaluation 
revealed 
concrete 
examples of 
benefits 
outweighing 
costs notably 
for specific 
EIS systems. 

In general, 
the evaluation 
has also 
assessed that 
the 
programme 
has 
contributed to 
a better 
application of 
Union law in 
the field of 
taxation and 
effective in 
supporting 

 
 
 
 
 
 
 
the fight 
against tax 
fraud, evasion 
and ATP, 
which can 
also benefit 
businesses. 

public. 

Also, some of 
the training 
may have 
been used to 
raise 
awareness 
and 
information. 

efficient 
in the 
provision 
of 
informati
on. Also 
they have 
also 
contribute
d to more 
efficient, 
simplified 
and 
standardis
ed 
procedure
s. 

Indirect 
benefits: 

2./3. The 
joint 
actions 
and 
trainings 
have 
contribute
d to more 
efficient, 
simplified 
and 
standardis
ed 
procedure 
and time 
savings.  

They have also 
contributed to more 
efficient, simplified 
and standardised 
procedures. 

2. The majority of tax 
authorities 
interviewed agreed 
that the benefits 
outweighed costs. 
Joint actions were 
assessed as providing 
good platforms to 
further develop the 
Automatic Exchange 
of Information and 
exchange experience 
and best practices for 
mutual learning and 
even enacting 
reforms. They have 
also contributed to 
developing some EIS 
systems and in turn 
more efficient, 
simplified and 
standardised 
procedures.  

3.Training has 
supported a better 
understanding of EU 
tax law and EIS 
knowledge and thus 
improved 
administrative 
capacity and a more 
coherent application 
of EU law. 

ANNEX V. STAKEHOLDER CONSULTATION – SYNOPSIS REPORT 

STAKEHOLDER CONSULTATION ACTIVITIES – METHODOLOGY AND APPROACH  

This  report  presents  the  stakeholder  consultation  activities  performed  within  the  context  of 
the  “Study  on  the  final  evaluation  of  the  Fiscalis  2020  programme”.  The  purpose  of  this 
report is to present the stakeholder groups consulted as part of the study and the consultation 
methods, topics covered, as well as the associated limitations. 

The stakeholder consultation activities conducted as part of this study our outlined in  Table 
16 below. 

89 

 
 
 
 
Table 16 : Overview of consultation activities 
Programme interviews 

Stakeholder type 

Number of interviews 

In-depth interviews 

DG TAXUD 

DG NEAR 

Fiscalis  national  coordinators  (AT, 
BG, HR, CY, EL, HU, LV, LT, MT, 
RO, SK, RS, ME, TK) 

Total 

2 

1 

14 

17 

Case study consultation 
activities 

In-depth interviews 

Stakeholder type 

Number of interviews/survey 
respondents 

National  authorities  (DE,  IE,  SE, 
NL,  IT,  BE,  FI,  DK,  FR,  CZ,  EE, 
LU, AT, BG, CY, PT, PL, SI) 

European business organisation 

EU  officials 
GROW) 

(DG  TAXUD,  DG 

Total 

30 

9 

7 

46 

26 

Survey (TNA Case study) 

TNA user (national tax officials) 

INTERVIEWS 

PROGRAMME LEVEL INTERVIEWS 

During  the  inception  phase  of  the  study,  two  exploratory  interviews  with  the  Fiscalis  team 
within  DG  TAXUD  were  held.  The  objective  of  these  interviews  was  to  gain  a  deeper 
understanding  of  the  programme  and  its  components,  as  well  as  data  availability  and  case 
study selection insights. An exploratory interview with DG NEAR staff was also conducted. 
At  a  later  stage,  exploratory  interviews  with  operational  and  IT  unit  staff  working  directly 
with the EIS (European Information systems) analysed were conducted (see Table 17). 

Moreover, 11 semi-structured targeted interviews were carried out with Fiscalis programme 
coordinators in  Member States that were not  interviewed in  the context  of the case studies. 
Three  Fiscalis  programme  coordinators  in  third  countries  (RS,  ME,  TK)  were  also 
interviewed. 

Overall, 17 semi-structured interviews were conducted with relevant stakeholders in the EU 
institutions,  as  well  as  with  Fiscalis  national  coordinators  both  in  EU  Member  States  and 
third  countries.  The  table  below  presents  a  full  overview  of  the  stakeholders,  which  were 
interviewed  as  part  of  the  programme-level  evaluation.  The  data  gathered  through  the 
interviews  was  coded,  analysed  and  categorised  into  themes  after  which,  triangulation  with 
additional data sources, provided insights into the evaluation questions.  

90 

 
 
 
Table 17: Stakeholders consulted as part of the program-level interviews 
Stakeholder 
group 

Stakeholder 
type 

Position 

Unit 

Number of 
interviews 

EU officials 

DG TAXUD 

Deputy Head of 
Unit 

TAXUD.C.4 

Project Manager  TAXUD.B.4 

Head of Sector 

DG NEAR 

Policy Officer - 

NEAR B.4 

Team Leader 

NEAR A.3 

Programme 
officer 

NEAR A.3 

National 
authorities 

Fiscalis 
programme 
coordinators 

Subtotal  

N/A 

AT 

BG 

HR 

CY 

EL 

HU 

LV 

LT 

MT 

RO 

SK 

RS 

ME 

TK 

1 

1 

1 

3 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

1 

Subtotal 

Total 

14 

17 

Number of 
interviewees 

1 

2 

3 

6 

2 

1 

1 

2 

1 

1 

2 

1 

1 

1 

1 

1 

1 

1 

17 

23 

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CASE STUDY CONSULTATION ACTIVITIES 

Each  case  study  included  the  collection  of  documentary  evidence  and  interviews  with 
stakeholder directly involved in the technical aspects of the Fiscalis EIS systems but also 
with  policy  officers.  The  stakeholder  consultations  were  adapted  to  each  case  study’s 
EIS.  

The exact number of interviews conducted per case study is presented in Table 18. 

Table 18: Stakeholders interviewed in the frame of the case studies 
Stakeholder group  Country 

Organisation 

Position 

Mini One Stop Shop (MOSS) 

National 
administration 

tax 

DE 

German Federal Tax Office  

IE 

SE 

NL 

Office  of 
Commissioners 

the  Revenue 

Swedish 
(Skatteverket) 

Tax 

Agency 

Fiscalis Coordinator, two 
VAT policy / MOSS 
experts 

Five interviewees, 
representing both the 
VAT policy side and the 
MOSS IT side. 

Three interviewees, 
representing both the 
policy side and the 
MOSS IT side 

Dutch  Tax  and  Customs 
administration 
(Belastingdienst) 

Dutch Tax and Customs 
administration 
(Belastingdienst) 

Subtotal tax administrations 

Economic 
operators 

IE 

Anonymous 

organisation 
Large 
representing  businesses  that 
make  use  of  MOSS,  provide 
tax advice 

MT 

Anonymous 

Small  organisation  (+-  40 
supporting 
employees) 
businesses 
VAT 
compliance,  notably  in  the 
gaming industry 

with 

EU officials 

DG TAXUD 

Subtotal economic operators  

Policy officer in VAT 
legislation 

(TAXUD.C.1) 

Policy assistant 
(TAXUD.C.1) 

92 

Number 
of 
interviewees 

5 

5 

3 

3 

16 

2 

1 

3 

2 

 
 
 
 
 
Stakeholder group  Country 

Organisation 

Position 

Number 
of 
interviewees 

Total 

21 

Transaction Network Analysis (TNA) 

National 
administration 

tax 

IT 

Revenue Agency 

FPS  Finance  -  Special  Tax 
Inspectorate 
(Belgium)/ 
TNA Operational team 

Tax Administration 

Revenue Ireland 

Tax Agency 

Revenue Agency 

General  Directorate 
Public Finance 

of 

Working Field 1 
coordinator 

Grant coordinator 

TNA user 

TNA user 

TNA user 

TNA user 

TNA user 

Federal Central Tax Office 

TNA user 

BE 

FI 

IE 

DK 

IT 

FR 

DE 

EU officials 

DG TAXUD 

Subtotal tax administrations 

IT Leader 
(TAXUD.B.4.) 
Policy Officer (TAXUD 
C.4) 

Subtotal EU officials 

Total 

System for Exchange of Excise data on Europa website (SEED) 

National 
administration 

tax 

CZ 

DK 

EE 

LU 

PL 

EU 

Economic 
operators 

General  Directorate 
of 
Customs,  Excise  Duties 
Division 

Head of Excise Liaison 
Office (ELO) and EMCS 
Department 

Danish Tax Agency 

Professional Consultant 

Tax and Customs Board 

Administration  of  Customs 
and Excise Duties 

Tax and Customs Board 
Chief Specialist Public 
Services 

Principal Inspector 

Subtotal tax administrations 

Imperial Tobacco 

European  Committee 
Wine Enterprises (CEEV) 

of 

UK/EU 

British American Tobacco 

EU officials 

DG TAXUD 

Subtotal economic operators  

Policy Assistant 
(TAXUD C.2) 

1 

1 

1 

1 

1 

1 

1 

1 

8 

2 

2 

10 

1 

1 

1 

1 

4 

1 

1 

1 

3 

1 

93 

 
 
 
 
 
 
 
Stakeholder group  Country 

Organisation 

Position 

Number 
of 
interviewees 

National 
administration 

tax 

AT 

Taxes in Europe Database (TEDB) 

Federal Ministry of Finance 

Policy officer 

Total 

DE 

BG 

CY 

FR 

BE 

FR 

PT 

Federal Ministry of Finance 

Two policy officers 

Ministry of Finance 

National expert 

Ministry of Finance 

VAT officer 

Tax official           

Directorate-General of 
Customs and Indirect Taxes 

Head of section 
Policy officer 

Federal Public Service 
Finance 

Advisor 

Directorate-General of 
Customs and Indirect Taxes 

Project manager 

Ministry of Finance 

Project manager 

EU officials 

DG TAXUD 

DG GROW 

DG TAXUD 

Subtotal tax administrations 

Deputy Head of Unit 

Policy Officer 

Policy Officer 

Subtotal EU officials 

Economic 
operators 

SE 

MT 

DE 

IT 

Anonymous 

Co-founder 

Anonymous 

Director Tax and VAT 

Anonymous 

Director Tax and VAT 

Anonymous 

Director Tax and VAT 

Subtotal economic operators  

8 

1 

2 

1 

2 

2 

1 

1 

1 

8 

1 

1 

1 

3 

1 

1 

1 

1 

4 

Total 

15 

94 

 
 
 
 
 
Stakeholder group  Country 

Organisation 

Position 

Number 
of 
interviewees 

Directive on Administrative Cooperation 1 and 2 (DAC1/2) 

National 
administration 

tax 

BE 

MINFIN 

Project leader in the 
international relations 
department of Belgium 
Finance Ministry 

FI 

FI 

FI 

PL 

SI 

Tax Administration (Vero) 

Senior Adviser 

Tax Administration (Vero) 

Risk Manager 

Tax Administration (Vero) 

Development expert 

National Revenue 
Administration Department 

Head of Unit 

Senior Advisors 

Financial Administration of 
the Republic of Slovenia  

Head of Division and 
Senior Advisor 

EU officials 

DG TAXUD 

Subtotal tax administrations 

Policy Officer Taxation 
(TAXUD.D.2) 

Total 

2 

1 

1 

1 

4 

2 

11 

1 

12 

For the TNA system, a survey was developed to reach a wider group of TNA users and to 
gather  a  better  understanding  of  their  experience  with  using  the  IT  system.  They  were 
also  invited  to  provide  additional  information  in  follow-up  interviews.  The  survey  was 
disseminated  with  the  assistance  of  the  coordinator  of  Eurofisc  Working  Field  1  on  18 
May  2021  and  it  was  open  until  1  June  2021.  Twenty-six  Eurofisc  Liaison  Officials 
responded, of which 24 completed the entire survey.  

PUBLIC CONSULTATION  

The  public  consultation  supporting  the  mid-term  evaluation  of  the  Fiscalis  2020 
programme was launched within the context of the Commission’s proposals for the next 
generation of financial programmes for the post-2020 Multiannual Financial Framework, 
which  is  the  EU’s  long-term  budget.  As  the  financial  framework  cuts  across  all  policy 
fields, the public consultation documents were divided in a number of thematic area. The 
Fiscalis 2020 programme was included in the public consultation on investment, research 
and  innovation,  SMEs  and  single  market.  This  consultation  covered  both  the 
retrospective and prospective elements of the Commission’s spending programmes. 

The consultation run for the period of 8 weeks and took place between 10th of January 
2018  and  9th  of  March  2018.  The  Secretariat  General  of  the  European  Commission 
sanctioned this derogation. The questionnaire was available in all EU languages.  

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Overall,  the  Commission  has  received  4052  replies  from  all  28  EU  Member  States, 
Norway, Iceland, Switzerland and 12 other countries. Around 60 % of replies came from 
just  six  countries:  Spain,  Italy,  Belgium,  Germany,  France  and  UK.  A  third  of  replies 
came from citizens (409), a third from companies (396), 16 % from NGOs and academia 
(180),  8 %  from  public  authorities  (89).  There  were  257  replies  from  individual 
companies  (93 %  of  which  were  SMEs)  and  95  replies  from  business  associations. 
National  public  authorities  from  14  EU  Member  States,  7  non-EU  Member  States  and 
regional or local authorities from 13 Member States participated in the consultations (see 
Figure 13). 

Respondents to this public consultation could choose between the four policy fields most 
important for them (investment, research and innovation, SMEs and single market). The 
general  objective  of  the  Fiscalis  2020  programme  being  to  support  the  functioning  and 
modernisation  of  taxation  systems  in  order  to  strengthen  cooperation  amongst  tax 
administrations  in  the  internal  market,  the  most  pertinent  area  of  consultation  in  the 
Fiscalis  2020  context  would  be  the  single  market.  It  was  indicated  by  approximately 
7.5 % of the respondents54.  

Figure 13: Distribution of answers to public consultation by country and stakeholder type 

54  The  remaining  fields  were  “EU  support  for  research  and  innovation”  (3837  answers,  95 % of  all  answers)  ,  “EU 
support  for  SMEs  and  entrepreneurship  ”  (1034  answers  –  25 %  of  all  answers,  “EU  support  for  Investment”  (642 
answers – 16 % of all answers); 

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CHALLENGES AND MITIGATION STRATEGIES 

Throughout  the  course  of  the  interviews,  several  challenges  were  encountered,  as 
presented in Table 19 below. 

Table 19: Problems and solutions for the interviews 

Problem/limitation  

Solution/mitigation  

Specific aspects of the IT systems were not widely 
known across each of the stakeholder groups.  

As  the  level  of  knowledge  and  experience  with  the 
Fiscalis  IT  system  was  different  for  the  different 
interview respondents, not all interviewees were able 
to  answer  to  questions  relating  to  all  evaluation 
criteria.  The  flexible  approach  to  the  design  of  the 
interview  guides  allowed  for  information  to  be 
gathered  taking  into  account  the  experience  of  the 
interviewee  with  the  Programme.  For  instance,  the 
focus  of  the  programme  level  interviewees  was 
placed on Joint Actions as Fiscalis coordinators were 
not  that  familiarised  with  certain  aspects  of  the  IT 
systems.  Where  limited  evidence  was  collected  on 
specific  funded  actions  and  areas  of  Fiscalis,  the 
other stakeholder groups (such as end users), as well 
as desk research helped to fill any gaps.  

Some stakeholders could not be reached 

struggled 

evaluation 

requests,  which 

reach 
it  difficult 

certain 
The 
to 
to 
stakeholders.  Respondents  found 
prioritise 
is  not 
information 
surprising, as Fiscalis has two evaluations per cycle, 
requiring  feedback  from  stakeholders  every  two  to 
three  years.  Efforts  to  reach  economic  operators  to 
assess  Fiscalis  2020  simplifying  effects  were  not 
successful,  it  was  not  possible  to  access  contact 
details  from  Member  States  and  several  economic 
operators contacted declined participation.  

KEY FINDINGS PER EVALUATION CRITERIA 

EFFECTIVENESS 

All  the  Fiscalis  national  coordinators  interviewed  agreed  that  Fiscalis  2020  has 
contributed to fighting tax fraud, tax evasion and aggressive tax planning. Coordinators 
reported  that  the  framework  provided  by  the  programme  enables  cooperation  and 
coordination among different tax administrations in the EU which in turn enhances their 
administrative  capacity  and  the  implementation  of  EU  taxation  law  through  knowledge 
sharing. The Eurofisc network, multilateral controls (MLCs), trainings and working visits 
were  perceived  as  very  relevant  by  Fiscalis  national  coordinators  to  achieve  the 
programme’s objectives.  

The  EIS  systems  are  perceived  to  significantly  reduce  the  administrative  burden  and 
compliance cost  for taxpayers according to  the majority of the interviewed national  tax 
administrations  in  the  MS.  In  the  context  of  the  MOSS  case  study,  national  authorities 

97 

 
 
interviewed  perceived  that  the  systems  were  most  about  compliance,  which  indirectly 
contributed to less tax evasion, than fighting fraud per se. They explained that businesses 
have  good  intentions  and  will  comply  with  rules  but  are  unable  to  do  so  if  not  well-
informed.  In  the  context  of  DAC1/DAC2,  national  authorities  consulted  acknowledged 
the  deterrent  effect  as  playing  an  important  role  in  reducing  tax  fraud  and  tax  evasion. 
National  authorities  interviewed  in  the  frame  of  the  SEED  case  study  agreed  that  the 
system  helped  to  minimise  fraud  as  only  authorised  economic  operators  can  used  the 
systems  allowing  a  better  tracking  of  the  movement  of  goods.  In  terms  of  enhancing  a 
common  understanding  of  the  implementation  of  EU  law,  national  authorities  in  the 
frame of the TEDB  case studies confirmed that the system  is  a  good tool to  find up to 
date information but that it is not sufficiently advertised.  

EFFICIENCY 

Generally,  interviewees  perceived  that  the  costs  are  proportionate  to  the  benefits 
generated by the programme, particularly in regard to EIS analysed. Regarding the Joint 
Actions (JA), one Fiscalis coordinator reported that the costs are justified depending on 
how much of the information  ends up being disseminated. One coordinator flagged the 
fact  that  changes  in  IT  systems  sometimes  imply  changes  in  national  systems  which 
comes with additional costs which need to be borne by national administrations. It is also 
important  to  highlight  the  fact  that  the  interviewed  national  coordinators  from  third 
countries reported that in some cases their contribution is not proportionate to the actual 
benefits obtained from the programme (i.e. given the fact that they do not have access to 
the IT systems). 

RELEVANCE 

There is wide consensus among key stakeholders interviewed on the fact that the Fiscalis 
2020  is  necessary,  relevant  and  responds  to  major  challenges.  However,  four  Fiscalis 
coordinators  interviewed  reported  lack  of  staff  and  limited  administrative  capacity  to 
address  these  challenges.  Moreover,  Fiscalis  coordinators  interviewed  in  candidate 
countries pointed out their limited capacity to benefit fully from Fiscalis-funded actions 
due to its EU-oriented nature. This adds to the fact that these countries do not have access 
to all IT systems, which affects their ability to take part in related training components. 
Another area for improvement highlighted by one of the coordinators was to better cover 
emerging  developments  affecting  taxation  such  as  the  new  VAT  One  Stop  shop  (OSS) 
and  Import-One-Stop-Shop  (IOSS)  schemes  aimed  at  facilitating  the  collection  and 
payment of VAT across MS, virtual currencies, digital solutions to combat fraud, etc. 

COHERENCE 

National  Fiscalis  coordinators  from  non-EU  countries  were  asked  about  the  TAIEX 
(Technical  Assistance  and  Information  Exchange 
the  European 
Commission)  and  whether  this  instrument  complemented  or  overlapped  with  Joint 

instrument  of 

98 

 
 
Actions  funded  by  Fiscalis  2020  Programme.  Overall,  non-EU  country  coordinators 
reported that it is complementary as it allows them to implement actions that can not be 
implemented by  Fiscalis (i.e. legislation). Moreover, a DG TAXUD officer (previously 
working for DG REFORM) interviewee 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 TSI. 

EU ADDED VALUE 

All  Fiscalis  coordinators  interviewed  acknowledged  the  importance  of  Fiscalis  2020 
Programme in enabling a common understanding of EU tax law among the different EU 
tax  administration.  When  asked  to  imagine  a  hypothetical  situation  where  the  Fiscalis 
programme  was  stopped  or  discontinued,  national  authorities  interviewed  agreed  that  it 
would have significant negative consequences such as 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.  One  Fiscalis 
coordinator pointed to collaboration with the OECD or the International Organisation of 
Tax Administrations (IOTA) as an alternative framework. However, he/she 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. 

ANNEX VI. MID-TERM EVALUATION RECOMMENDATIONS 

This  annex  contains  the  recommendations  coming  out  of  the  mid-term  evaluation  to 
improve the programme, and the state of their implementation at the date of March 2022. 
The  recommendations  are  based  on  the  findings  and  conclusions  presented  in  the  mid-
term  study  report  and  are  structured  in  themes  that  relate  to  different  aspects  of  the 
programme. Since responsibility for implementing the recommendations is split between 
the  Commission  services  and  national  tax  administrations,  we  also  specify  who  should 
take action in each case, and according to what time frame. 

Based on the input provided by the studies, the Commission set-up an Action Plan that 
responds to each of the recommendations outlined in the evaluation studies, specifying  
the extent to which and how the recommendations can be implemented. 

It should be emphasised that the results of the evaluation are generally positive. While 
there is room for improvement in certain areas, these amount to tweaks to a programme 
that on the whole is relevant, working well and adding value. It follows from this that the 

99 

 
 
 
Fiscalis programme should be continued and that, in the next funding period, a 
similar programme will be needed to consolidate the achievements made so far and to 
address the needs of target audiences as well as the EU more generally. 

Programming and design 

Recommendation 1: 

Make more practical use of the Annual Work Programme 
projects and consider multi-annual programming 

Responsible actor 

DG TAXUD 

Timeframe  

Short-term and for the next funding period 

Background 

Recommendation 

By  grouping  planned joint  actions (other  than  procurement)  into a 
series  of  thematically-linked  projects,  the  current  programme 
improved  on  previous  funding  periods,  which  simply  presented 
long  lists  of  loosely  related  activities.  The  idea  was  to  boost  the 
effectiveness and coherence of the programme by ensuring different 
funded joint actions support and complement each other better.  

However,  the  evaluation  found  that  this  potential  is  not  fully 
realised, since few stakeholders actually know about the projects 
or refer to them in any practical way. Similarly, despite the  multi-
annual  nature  of  many  of  the  funded  activities  (such  as  long-
term  project  groups  and  IT  development  projects),  the  planning 
process is annual, leading to a lot of repetition and making it hard 
for  stakeholders  to  engage  actively,  given  the  limited  time  and 
in  many  national 
resources 
administrations. 

faced  by  customs  officials 

In the short term, DG TAXUD could  make the projects come to 
life simply by referring to and discussing them more regularly 
(and  based  on  ad  hoc  needs)  with  national  coordinators,  DG 
TAXUD  officials  and  other  users  of  the  programme.  Setting  up 
common PICS groups for relevant actors could also be considered. 
Knowledge sharing around the identified policy projects could also 
increase their relevance. 

In  the  longer term  (as  is  already  proposed  for the  next  period)  we 
recommend that a multi-annual programming process is put in 
place that would correspond better to the nature the programme and 
the  activities  it  supports.  Such  a  multi-annual  process  could  be 
flexible,  setting  broad  priorities  that  are  still  operationalised  in 
annual  programmes,  with  some  contingency  for  emerging  needs. 
This  would  help  further 
the  coordination  between 
increase 
activities,  improving  the  quality  of  planning  documents  and  their 
practical implementation as well as the programme’s coherence. 

100 

 
 
 
Recommendation 2:  

Designate long-term, platform-like project groups as such 

Responsible actor 

DG TAXUD 

Timeframe  

Next funding period 

Background 

Recommendation 

The  evaluation  found  that  while  some  project  groups  are  highly 
focused  and  aimed  at  generating  well-defined  outputs,  other 
project groups are quasi-permanent platforms used for various 
types  of  coordination.  The  current  reporting  and  monitoring 
structure is  good  at  dealing  with  the  first type.  However,  it  is  less 
suited  to  defining  expectations  and  goals,  and  monitoring  the 
outputs and results of actions that fall into the second category. This 
in  turn  makes  it  difficult  to  figure  out  when  such  actions  are 
successful  and  make  decisions  about  whether  or  not  to  support 
them.  

When the operational details of the next programme are defined, we 
recommend  categorising  platform-like  project  groups  as  such, 
and  defining  and  applying  appropriate  criteria  for  funding 
applications  and  monitoring.  This  would  make  it  easier  to  take 
funding  decisions  about  these  actions,  gauge  success  and  learn 
lessons that can be used for future improvements.  

Recommendation 3:  

Refine strategy for development and promotion of elearning 
modules 

Responsible actor 

DG TAXUD and national administrations  

Timeframe  

Short-term and for the next funding period 

Background 

The  evaluation  showed  that,  while  the  elearning  modules  are  of 
high  quality,  participating  countries  have  different  training 
needs  and  curricula.  This  means  that  while  some  countries, 
especially  those  with  fewer  resources,  have  fully  integrated  (some 
of)  the  modules  into  their  curricula,  others  make  them  available 
more  as  a  complement  to  existing  material  while  in  a  number  of 
countries the modules are not used at all.  

Despite  these  differences,  the  modules  are  designed  with  all 
participating countries in mind, while yearly targets focus mainly 
on  increasing  the  number  of  administrations  who  use  them.  This 
makes it hard to establish realistic benchmarks for progress, and to 

101 

 
 
 
 
Recommendation 

tailor the training offer to the most important needs.   

We recommend developing a strategy based more on addressing 
identified  training  needs.  A  first  step  could  be  an  initial  survey 
conducted  with  the  help  of  the  Training  Support  Group  to  take 
stock of needs and interest. Leading from this, a strategy could be 
devised, ideally for multiple years, listing priorities to be taken up 
in future training modules and promotional plans. Importantly, this 
could mean prioritising those countries whose needs and likelihood 
to actually use the modules are greatest.  

Recommendation 4:  

Investigate ways to improve the technological platform for the 
delivery of elearning modules 

Responsible actor 

DG TAXUD and national administrations  

Timeframe  

Short-term and for the next funding period 

Background 

Recommendation 

there  are  many 
the  evaluation  findings, 
As  evidenced  by 
participating  countries  which  report  difficulties  accessing  modules 
due  to  technical  issues  and  lack  of  an  easy  fit  with  their  own 
learning  management  systems.  A  better  adapted  platform  would 
also allow for better reporting of usage as well as feedback.  

We  recommend  exploring  alternative  solutions  that  currently 
exist  on  the  market  which  could  meet  participating  countries’ 
needs in terms of security, limited distribution, central management 
and flexibility.  

Best  practices  and  synergies  could  also  be  identified  with  other 
Commission services and initiatives, in particular the OECD. 

Recommendation 5:  

Improve the procedures for the translation, localisation and 
updates to elearning modules 

Responsible actor 

DG TAXUD and national administrations  

Timeframe  

Short-term and for the next funding period 

Background 

Evaluation findings showed that language, localisation and updates 
to  elearning  are  critical  for  the  success  and  use  of  the  modules. 
Translation to local languages is considered particularly important 
for modules that target operational issues, which often involve the 
training of front-line staff.  

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In  terms  of  localisation  and  updates,  the  content  of  the  modules 
needs  to  reflect  local  specificities  and  be  flexible  to  incorporate 
changes in legislation or IT systems to remain relevant to the target 
audiences. 

We recommend prioritising an agile and flexible management of 
elearning  modules,  focused  on  improving  the  procedures  for  the 
translation of the modules and on facilitating quick localisation and 
updates  of  the  training  material.  In  relation  to  translation  of  the 
elearning  modules,  we  suggest  communicating  more  clearly  that 
participating  countries  can  request  at  any  moment  the  localisation 
of  an  EU  elearning  course  through  the  signature  of  partnership 
agreements  with  the  Commission,  and  that  no  requests  have  been 
turned  down  in  the  current  programming  period.  If  participating 
countries  miss  the  window  of  opportunity  for  the  translation  of  a 
given module, it is purely because of national limitations. 

In  relation  to  localisation  and  updates  to  the  elearning  modules, 
alternative strategies should be investigated to facilitate changes 
in  the  content  of  the  modules  to  reflect  local  characteristics  as 
well  as  emerging  issues,  such  as  new  legislation,  changes  in  IT 
systems and guidelines. 

Implementation 

Recommendation 6:  

Increase coordination with other EU programmes 

Responsible actor 

DG TAXUD and other Commission DGs 

Timeframe  

Short-term and for the next funding period 

Background 

In terms of synergies with the Customs programme, the evaluation 
(as well as the parallel evaluation of the Customs programme and a 
recent  Court  of  Auditors  report)  found  that,  while  the  two 
programmes share an organisational structure and a number of 
activities, there was still a lack of coordination. This means that 
potential synergies in areas such as e-commerce, VAT fraud and IT 
system development have not been fully realised, and that there is 
room for translating relevant lessons learned in one programme to 
the other, in particular in the context of horizontal joint actions, IT 
systems and training modules that cut across both programmes. An 
example  of  the  potential  there  is  for  exchanging  experiences 
between  the  two  programmes  is  the  Electronic  Customs  Multi-
Annual  Strategic  Plan  (MASP),  a  management  and  planning  tool 
drawn  up  by  the  Commission  in  partnership  with  Member  States, 
which  sets  out  a  strategic  framework  and  milestones  for  the 

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management  of  new  IT  projects  in  the  area  of  customs.  The 
development  of  this  tool  under  Fiscalis  should  feed  from  the 
Customs initiative. 

two  programmes  explore  opportunities 

In relation to Customs and Fiscalis cooperation, we recommend that 
to  enhance 
the 
operational  coordination  and  the  sharing  of  information  on 
shared  components,  including  IT  systems  and  approaches  for 
human  competency  building  and  training.  The  Multi-Annual 
Strategic Plan for Customs European Information Systems and the 
EU Common Framework for Customs should serve as baselines and 
examples  for  the  development  and  implementation  of  these 
initiatives under Fiscalis. Flagship Fiscalis initiatives should also be 
identified that could be taken as examples in Customs. 

In  relation  to  Fiscalis  cooperation  with  other  Commission  DGs, 
while acknowledging that officials in DG TAXUD and other DGs 
are  already  burdened  with  meetings  and  other  obligations,  we 
recommend  that  a  common  coordination  forum  is  established 
between  relevant  officials  in  DG TAXUD,  DG  GROWTH, 
DG HOME,  DG  ECFIN  and  OLAF  in  particular.  This  could 
start with a single meeting and evolve as appropriate, with a view to 
establishing more formal links and identifying and exploiting more 
links where possible. 

Recommendation 7:  

Optimise the procedures and resources for the implementation 
of joint actions  

Responsible actor 

DG TAXUD and national administrations 

Timeframe  

Short-term and for the next funding period 

Background 

sometimes 

requirements 

To  ensure  that  the  EU  budget  is  spent  in  line  with  the  overall 
principles  and  the  objectives,  the  programme  procedures  require 
various steps regarding the different action types mainly to initiate 
and  to  report  on  joint  actions.  However,  these  administrative  and 
procedural 
as 
disproportionate to the level of the EU investment (e.g. the approval 
of  a  regional  workshop  with  ten  participants,  currently  may  take 
more  than  two  months  and  requires  multiple  consultation  and 
review cycles). This seems to be the case in particular in terms of 
working visits, expert teams, and for smaller one-off events. At the 
same  time,  the  lack  of  sufficient  human  resources  both  at  the 
Commission  and  in  national  administrations  may  reduce  joint 
actions’  agility  and  put  too  much  pressure  on  the  officials 

considered 

are 

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responsible  for  implementing  and  reporting  on  the  programme.  of 
the  implementation  of  joint  actions  and  create  a  sub-optimal 
workload and pressure on the staff. 

We  recommend  that  DG  TAXUD,  where  appropriate  involving 
national  coordinators,  review  the  workload  for  existing  human 
resources and the steps for applying for and reporting on joint 
actions,  with  the  aim  of  establishing  more  effective  and  efficient 
administrative  processes  and  reducing  the  workload  on  staff.  This 
could entail the introduction of a project-based approach (replacing 
an event-based management) that would reduce micro-management 
and  related  administrative  burdens.  Resulting  in  the  reduction  of 
micro  management  and  related  administrative  burden.  The  central 
and  national  programme  management  levels  could  also  produce 
easy-to-use guides and templates to lighten the burden.  

Monitoring and reporting 

Recommendation 8:  

Streamline the monitoring system so that it meets actual needs 
while reducing administrative burdens 

Responsible actor 

DG TAXUD 

Timeframe  

Short-term and for the next funding period 

Background 

The performance measurement framework that was put in place for 
the  current  funding  period  has  undoubtedly  added  value  by 
providing  evidence  for  accountability  purposes.  However,  it  has 
also  added  heavy  reporting  burdens  without  leading  to  more 
evidence-based decision-making.  

is  rarely  collected  and 

This is due to several inter-related factors, such as: there are too 
many  indicators;  indicators  at  impact  level  that  are  based  on  data 
the 
that 
programme’s  achievements;  there  are  so  many  forms  that  they 
become  a  tick-box  exercise;  programme  managers  are  driven  to 
distraction  by  the  amount  of  data  to  process  (often  manually)  and 
report  on;  annual  progress  reports  come  out  too  late  in  the 
programming process.  

to  connect 

impossible 

to 

Recommendation 

A  simplified  framework  could  be  both  more  useful  and  less  time-
consuming  for  stakeholders.  In  the  short  term,  DG TAXUD  could 
put in place some quick fixes to reduce burdens on programme 
managers  and  participants.  For  example,  the  action-follow-up 
form and event assessment form could be simplified so as to place a 
smaller burden on participants. DG TAXUD could also focus on a 

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limited  number  of  core  indicators  rather  than  reporting  equally  on 
all  of  them,  especially  given  numerous  overlaps  and  some 
inconsistencies. 

We  also  recommend  that  DG TAXUD  conduct  an  evaluation  of 
the 
the  performance  measurement  framework 
monitoring  system 
to  specific 
in  detail.  This  should 
recommendations  to  reduce  the  number  of  indicators  and 
eliminate  irrelevant  indicators  and  overlaps  in  order  to  ultimately 
lighten  administrative  burdens  and  establish  firmer  links  between 
monitoring and performance management.  

to  assess 

lead 

Since  indicators  at  impact  level  relate  more  directly  to  specific 
customs  policies  than  to  the  programme,  a  small  set  of  impact 
indicators  has  been  defined  for  data  collection  during  monitoring 
and evaluation of these policies. In theory, the data collected should 
then be made available to the programme management unit to feed 
into  the  monitoring  system.  However, for  this to  work,  the impact 
indicators, monitoring and evaluation of relevant policies will need 
to  be  used  to  collect  data  on  these  indicators  at  regular  and 
sufficiently  frequent  intervals.  The  evaluation  of  the  Performance 
Measurement Framework should assess this challenge and propose 
recommendations for tackling it. 

Other  changes  are  also  worth  exploring.  For  example,  some 
surveys  and  satisfaction  forms  could  be  replaced  by  less  frequent 
(but more in-depth) consultations with key stakeholders. Electronic 
tools  for  data  collection,  analysis,  and  presentation  (such  as 
automatically updating dashboards) could reduce the effort needed 
for  these  tasks  while  making  the  reports  more  timely  and  usable. 
Since much of the programme’s achievements rely on networking, 
coming up with indicators on this should be a priority.  

Recommendation 9:  

Develop a more coherent approach to assessing programme 
performance 

Responsible actor 

DG TAXUD 

Timeframe  

Next funding period 

Background 

The Multiannual Financial Framework programming cycle typically 
requires  DG  TAXUD  to conduct  several  exercises  that  require 
input  from  national  administrations  (e.g.  studies,  progress 
reports).  Parallel  to  the  present  evaluation,  these  included  an  ex 
ante  evaluation for the next funding period, a mid-term evaluation 
of  the  Customs  2020  programme  and  impact  assessment  for  that 

106 

 
 
 
programme’s  successor.  All  of  these  studies  included  consultation 
with  overlapping  sets  of  stakeholders  and  significant  effort  from 
programme  managers. The need for two full evaluations (i.e. mid-
term  and  final)  per  programme,  per  funding  period  also  generates 
considerable burdens.  

The  combined  effect  is  to  produce  consultation  fatigue  and  a 
reluctance among stakeholders to engage multiple times with the 
various studies. This undermined the robustness of the work carried 
out and thus the evidence base for future decision-making.  

Recommendation   

While  certain  requirements  are  fixed,  there  are  several  options  for 
reducing the burden on national administrations. These include: 

  Combine  the  impact  assessment  /  ex  ante  evaluation  of  future 
funding  periods  with  the  mid-term  evaluation  of  the  current 
period, which several DGs (such as DG Education and Culture) 
have done successfully. 

  Make  the  mid-term  evaluation  lighter,  focused  more  on 
operational matters and implementation. This could be sensible, 
especially considering that many impacts cannot be identified at 
such an early stage of implementation.  

related 

their  results 

  Combine  studies 

the  Fiscalis  and  Customs 
to 
programmes.  This  would  build  on  the  coordinated  approach 
taken  to  the  present  mid-term  evaluations  and  further  reduce 
overlap and the duplication of administrative and other work as 
well as helping to generate synergies between the programmes. 
  Undertake  more  evaluations  focused  on  policy-related  issues, 
and  use 
inform  smaller,  more  focused 
evaluations of the programme. Each policy evaluation in the tax 
area, particularly areas that draw from the programme support, 
should  regularly  and  specifically  examine  the  role  of  the 
the  programme-funded  IT 
Fiscalis  programme, 
systems.  Successive  programme  evaluations  have  provided 
evidence  that  the  programme  is  successful  and  that  major 
changes  are  not  required.  What  could  be  more  relevant  would 
be  the  assessment  of  key  policies  and  how  well  the  various 
programme instruments and activities support them. 

including 

to 

Recommendation 10:  

Improve reporting and information-sharing tools  

Responsible actor 

DG TAXUD 

Timeframe  

Next funding period 

Background 

The  PICS  information  sharing  tools  and  ART  reporting  tool  are 
crucial, both for the everyday functioning of the programme and for 
sharing  information  securely  in  support  of  objectives  such  as 
increasing  administrative  cooperation.  However,  they  have  been 

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criticised  for  a  lack  of  user-friendliness  that  wastes  time  and 
prevents  them  from  realising  their  potential.  Moreover,  some 
supported activities rely on CIRCABC, another information-sharing 
tool  developed  outside  DG  TAXUD  that  was  also  criticised  for  a 
lack of user-friendliness.  

We  recommend  that  DG  TAXUD  conduct  an  (internal  or 
external)  audit  of  these  tools  and  their  use  and,  based  on  the 
results,  decide  on  next  steps.  Given  shifting  security  and  file-
sharing  needs,  PICS  in  particular  could  be  either  revamped  or 
replaced,  while  ART  could  be  refined  so  that  its  formidable 
functionalities are made more user-friendly.  

in 

stakeholders 

Any changes should then be communicated in an accessible way 
to 
the  Commission  and  administrations, 
particularly  the  national  coordinators  who  are  responsible  for 
sharing  information  about  the  programme  among  potential  joint 
action and training participants. Such communication could include 
online tutorials as well physical training sessions as appropriate.  

Communication 

Recommendation 11:  

Increase senior-level buy-in and political will 

Responsible actor 

National administrations  

Timeframe  

Both short-term and for the next funding period 

Background 

Recommendation 

Buy-in  and  political  will  from  the  senior  leadership  of  national 
administrations is vital to securing engagement with the programme 
and  a  critical  mass  of  participation  in  specific  activities.  In  most 
cases  this  was  present,  but  in  some  countries  it  was  not,  taking 
collaboration  down  the  list  of  priorities  and  contributing  to  low 
participation rates.  

Since  many  activities  rely  on  network  effects  and  active 
collaboration,  the  lack  of  engagement  from  some  countries  also 
affects  the  programme’s  potential  more  widely.  This  is  especially 
the case for actions based on sharing experiences and best practices 
between countries. 

that 

recommend 

the  senior 

leadership  of  national 
We 
administrations engage more actively with the programme, with 
a view to expressing any concerns or needs that are not being met 
and helping DG TAXUD to address them. National coordinators, as 
the  ‘ambassadors’  of  the  programme  in  their  respective  countries, 
have  a  particular  role  to  play  in  communicating  about  the 

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programme  throughout  their  administrative  hierarchies.  This  is 
especially true in candidate countries, some of which participate 
relatively little in the programme.  

Recommendation 12:  

Communicate more actively about the possibilities of the 
programme 

Responsible actor 

National administrations  

Timeframe  

Both short-term and for the next funding period 

Background 

Recommendation 

especially  new 

Similarly,  the  evaluation  found  that  the  limited  uptake  of  certain 
activities, 
as 
communication  and  monitoring  actions  and  expert  teams,  was  due 
in  part  to  insufficient  promotion  at  both  European  and  national 
levels.  

instruments 

funding 

such 

We  recommend  that  national  coordinators  and  other  officials 
take  a  more  active  role  in  finding  out  about  and  spreading 
awareness  of  the  possibilities  of  the  programme  within  their 
administrations. Relevant action could range from sharing materials 
produced  by  DG  TAXUD  on  local  intranets  and  translating  such 
materials  to  organising  information  sessions  and  asking  other 
administrations for success stories and other forms of assistance. 

Recommendation 13:  

Review strategy for dealing with economic operators and 
citizens 

Responsible actor 

DG TAXUD and national administrations 

Timeframe  

Both short-term and for the next funding period 

Background 

Economic  operators  and  citizens  more  widely  are  important 
secondary  audiences  for  the  programme,  but  awareness  and 
engagement  appeared  low  despite  strong  potential  interest  and 
the  existence  of  a  communication  strategy.  Moreover, 
the 
evaluation  did  not  find  a  clear  view  among  stakeholders  about 
whether and to what extent such groups should be pursued as target 
audiences beyond economic operator representation in certain joint 
actions  and  use  of  certain  IT  systems  and  elearning  modules.  The 
level  of  priority  for  getting  economic  operators to  use  the  training 
modules appeared particularly unclear, with promotional activity ad 
hoc rather than systematic.  

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Recommendation 

We  recommend  that  DG  TAXUD  review  the  communication 
strategy  for  the  programme,  with  a  view  to  arriving  at  a 
common  understanding  of  whether  and  to  what  extent  actors 
beyond  administrations  should  be  targeted.  This  could  include 
some  intermediate  action,  such  as  surveying  certain  subsets  of 
economic  operators  to  gauge  needs  and  interest.  Later  on,  DG 
TAXUD  could  decide  whether  any  Fiscalis  branding  would  be 
appropriate,  and  design  activities  for  reaching  given  types  of 
stakeholders. 

110