REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on the evaluation of the EU Framework for VAT administrative cooperation
Date: 2025-11-14
Institutions: Directorate-General for Taxation and Customs Union, European Commission
Subjects: European tax cooperation, VAT, administrative cooperation, digital economy, exchange of information, fraud, information system, intra-EU trade, tax offence

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 14.11.2025  COM(2025) 686 final  REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on the evaluation of the EU Framework for VAT administrative cooperation {SWD(2025) 350 final}  
 
 
1. 

INTRODUCTION 

Value Added Tax (VAT) is a harmonised consumption tax in the European Union (EU), 
levied on the sale of most goods and services, including cross-border transactions between 
Member States, as well as on imports. It represents a major source of revenue for Member 
States and contributes directly to the EU budget. Safeguarding the EU’s financial interests 
as  well  as  the  smooth  functioning  of  the  internal  market  requires  a  comprehensive  EU 
framework for the cooperation between Member States to ensure that VAT on goods and 
services  is  correctly  applied  and  fraud  is  addressed  with  adequate  means.  To  put  the 
challenge of controlling VAT on intra-EU transactions into perspective, the transactions 
between Member States were valued at EUR 4.135 trillion in 20231 with 6.5 million active 
traders2.  The  VAT  losses  due  to  the  most  common  VAT  fraud  scheme  called  Missing 
Trader in Intra-Community (MTIC) fraud represent EUR 12.5 billion to EUR 32.8 billion 
annually3. 

In the last few years, the EU has taken a number of landmark decisions to strengthen this 
cooperation without overburdening taxable persons with reporting obligations. The most 
recent such decision was the adoption of the VAT in the Digital Age Package4 on 11 March 
2025. With the new digital reporting obligations that will enter into force in 2030, Member 
States  will  be  better  equipped  to  address  cross-border  VAT  fraud  and  safeguard  their 
revenues. In 2020, the EU decided to tackle e-commerce VAT fraud with the use of cross-
border payment data obtained from payment service providers5. Since January 2024, the 
data are at the disposal of anti-fraud experts and the first report on the results is expected 
in  the  coming  months.  In  2018,  anti-fraud  measures  in  the  EU  framework  for  VAT 
administrative cooperation were significantly reinforced by allowing Eurofisc (a network 
of anti-fraud experts) to jointly process VAT data in order to identify VAT fraud. This has 
allowed a quantum leap in the fight against VAT fraud at EU level. 

The  purpose  of  the  present  report  on  the  evaluation  of  the  EU  framework  for  VAT 
administrative cooperation6 is to inform the European Parliament and the Council of the 
findings of the evaluation that the Commission conducted between 2023 and 2024 as well 
as  the  proposed  way  forward.  It  also  serves  as  the  report  that  the  Commission  submits 
every five years to the European Parliament and the Council on the application of VAT 
administrative cooperation7.  

1 

https://ec.europa.eu/eurostat/statistics-explained/index.php?title=Intra-EU_trade_in_goods_-
_main_features  

2  Based on annual statistics provided by Member States.  

3 

4 

Study  on  the  VAT  compliance  gap  due  to  Missing  Trader  Intra-Community  (MTIC)  fraud  of  2024. 
https://op.europa.eu/en/publication-detail/-/publication/dd40080c-bd27-11ef-91ed-
01aa75ed71a1/language-en  

https://taxation-customs.ec.europa.eu/taxation/vat/vat-digital-age-vida_en 

5  Council  Directive  (EU)  2020/284  as  regards  introducing  certain  requirements  for  payment  service 
providers  and  Council  Regulation  (EU)  2020/283  as  regards  measures  to  strengthen  administrative 
cooperation in order to combat VAT fraud. 

6  Council Regulation (EU) No 904/2010 on administrative cooperation and fight against fraud in the field 

of VAT; OJ L 268, 12.10.2010, p. 1–18.  

7  Article 59 of the Council Regulation (EU) No 904/2010. 

 
 
 
2.  FINDINGS OF THE EVALUATION 

The  evaluation  analyses  the  functioning  of  the  EU  framework  for  VAT  administrative 
cooperation  using  the  standard  evaluation  criteria  (effectiveness,  efficiency,  relevance, 
coherence and EU added value) to assess all the means of cooperation provided for by the 
underlying Council Regulation (EU) No 904/2010 on administrative cooperation and fight 
against fraud in the field of VAT. They are arranged in the following categories: 

•  Exchange  of  information  allows  tax  administrations  to  request  additional 
information about taxable persons to assist in the national control procedures; 
•  Cross-border audits allow tax administrations to create a multinational audit team 

to jointly analyse the VAT situation of companies; 

•  Shared data: the VAT Information Exchange System (VIES) contains all data on 

cross-border transactions between Member States; 

•  Eurofisc: a network of anti-fraud experts from tax administrations that can jointly 
process information to identify fraud and act as an early warning mechanism; 
•  Providing information to taxable persons allows taxable persons to verify the 
validity  of  the  VAT  number  of  a  customer  in  another  Member  State  before 
supplying goods and services. 

While  the  staff  working  document  accompanying  the  report  provides  details  on  the 
different forms of cooperation, the present report offers a concise overview of the most 
important findings of the evaluation.  

2.1.  Effectiveness 

The effectiveness of the different means of cooperation in the field of VAT was assessed 
with regard to the following specific objectives of the EU framework:  

• 

• 

• 

to improve the use of the existing administrative cooperation instruments in 
the  field  of  fighting  VAT-related  fraud  and  to  improve  the  exchange  of 
information between Member States; 
to  contribute  to  fighting  VAT  fraud  through  rapid  and  more  effective 
identification and dismantling of fraudulent networks related to VAT; 
to  improve  the  multidisciplinary  approach  to  fighting  and  preventing  VAT-
related  fraud  through  swifter  and  more  coordinated  reaction  capacity  and  better 
access to VAT information by different authorities (administrations, customs, law 
enforcement and prosecution authorities). 

On  the  first  objective,  the  EU  framework  continues  to  improve  administrative 
cooperation in the field of VAT by providing the legal base that is translated into several 
cooperation  tools  that  enable  Member  States  to  effectively  work  together.  These  tools 
should be seen as a toolbox which tax administrations can use according to their needs. 
Member  States  appreciate  it  as  an  asset  of  the  EU  framework  for  VAT  administrative 
cooperation.  

Among  the  different  cooperation  tools,  the  exchange  of  information  may  be  the  most 
visible  but  is  less  frequently  used  compared  to  the  past.  The  number  of  exchanges  of 
information on request, for instance, has decreased by almost 25% over the last six years 
to stabilise at 30 000 exchanges in 2023. This kind of cooperation is well established in the 
EU framework for VAT administrative cooperation. However, in 28% of the cases, the 
complete information is received after the deadline of 30 days. This renders the information 

2 

 
received  less  valuable  and  hinders  the  capability  of  Member  States  to  initiate  effective 
actions against fraud. As a result, there has been a continuous shift towards more efficient 
cooperation means, such as Eurofisc. A similar observation has been made for cross-border 
audits. Member States used to launch more such audits, then seen as an effective means 
for  addressing  carousel  fraud.  With  the  development  of  Eurofisc,  however,  the  same 
information  can  be  gathered  faster  and  without  the  need  for  coordinated  cross-border 
audits.  

Member  States  consider  Eurofisc  to  be  the  most  effective  means  of  cooperation  and 
appreciate the flexibility that the network offers. Experts appointed by their authorities to 
cooperate in the network work closely together on a daily basis and can reply to requests 
without the need for a lengthy exchange of information. Eurofisc is also  equipped with 
custom-built electronic tools that automate data collection and perform preliminary risk 
assessment,  tasks  that  were  done  manually  before  2019.  This  allows  to  better  leverage 
expertise and focus on final analyses. Member States appreciate that they receive  fraud 
signals that are substantiated with background analysis and an estimation of potential VAT 
losses. Necessary anti-fraud action can be taken faster without the need to consult other 
countries again.  

Finally,  the  EU  framework  also  serves  taxable  persons  by  assisting  intra-EU  traders  in 
fulfilling their obligations to check the validity of the VAT number of their customer in 
another Member State. VIES is consulted for that purpose up to 17 million times per day 
and its usage improved during the period covered by the evaluation. Traders appreciate the 
immediate  confirmation  of  the  information  provided  by  the  customer.  The  system  also 
allows traders to save the proof that they performed the validation, which they can then 
present to the tax authorities in case of an audit. 

On the second objective on contributing to the fight against VAT fraud, the evaluation 
focuses on Eurofisc as the central tool used by Member States to detect cross-border VAT 
fraud. Owing to its functioning and results, Eurofisc is highly appreciated by its primary 
users, Member State authorities. It fulfils their needs in terms of anti-VAT fraud analysis 
for cross-border transactions. The network identified EUR 14.8 billion worth of suspicion 
of  fraud  in  2024.  This  would  translate  into  EUR  3  billion  of  potential  VAT  losses. 
Compared  to  the  MTIC  gap  study  of  2024,  this  amount  represents  only  24%  of  the 
estimated lower level of MTIC fraud. This suggests that Eurofisc should discover more 
cross-border  VAT  fraud.  The  evaluation  has  identified  possible  means  for  improving 
Eurofisc effectiveness that will be described further in this report. 

Eurofisc  covers  well  the  needs  of  Member  States  for  fighting  VAT  fraud  through 
administrative means. Moreover, its results improve on average by 20% every year and 
access to new sources of information like customs data and information on car registrations 
have  increased  Eurofisc’s  capacity  to  detect  cross-border  VAT  fraud  significantly.  The 
evaluation  also  reveals  that  additional  information,  including  beneficiary  ownership 
registers and bank data, could enable the network to identify new fraudulent networks by 
finding connections that are not visible in VAT data alone. 

3 

 
 
Table 1: Amounts of VAT fraudulent transactions detected by Eurofisc using Transaction Network 
Analysis 8 

Amount of fraudulent or suspicious 
transactions uncovered (in millions 
EUR) related to Missing Traders in 
Intra-Community 
Amount of fraudulent or suspicious 
transactions uncovered (in millions 
EUR) related to vehicles  
Number fraudsters identified 

2020 

2021 

2022 

2023 

2024 

3 300 

8 100 

10 874 

12 735 

12 100 

N/A 

N/A 

N/A 

1 899 

2 700 

2 093  

2 161  

2 907  

5 171 

6 147 

Number of VAT deregistrations 

495  

775  

1 942 

2 995 

2 665 

On  the  last  objective  of  improving  the  multi-disciplinary  approach  to  tackling  VAT 
fraud, the conclusion of the evaluation is that the EU framework has failed in this regard. 
The  possibilities  that  the  EU  framework  offers  for  exchanges  with  the  European  Anti-
Fraud Office (OLAF) and the EU Agency for Law Enforcement Cooperation (Europol) 
are not  used or used  only  sporadically, due to  the fact  that such exchanges  cannot  take 
place at the initiative of OLAF nor of Europol, but can only be triggered by Eurofisc. In 
the case of OLAF, Eurofisc has never exploited this possibility, and in the case of Europol 
rarely. Thus, Member States still prefer to use the national channels for reaching out  to 
OLAF or Europol rather than the possibilities offered by the EU framework. Moreover, 
direct access to VAT information exchanged under the EU framework is reserved to tax 
authorities and in some limited cases to customs. However, this information is crucial for 
other  authorities 
law 
enforcement authorities and EU bodies.  

investigating  cross-border  VAT  fraud, 

including  national 

OLAF  has  concluded  administrative  investigations  on  customs  fraud  cases  with 
recommendations for recovery of evaded duties in the amount of approximately EUR 1.12 
billion  for  the  period  2022-2024.  Europol  has  provided  valuable  support  to  the  
investigations conducted by the European Public Prosecutor’s Office (EPPO), and it also 
receives  relevant  data  only  directly  from  national  law  enforcement  authorities  on  a 
voluntary basis. These cases are inextricably linked to VAT evasion at import and OLAF 
has informed the  relevant  national  authorities of its findings  related  to  evaded VAT, to 
enable actions at national level to be taken. As the European Court of Auditors (ECA) has 
found  in  its  Special  Report  No  8/2025,  even  though  until  recently  Member  States’ 
cooperation with OLAF in customs and tax matters in the case of CP42 fraud was limited 
to undervaluation fraud, in 2024, OLAF started focusing and cooperating with  Member 
States on the evasion of import duties and VAT for goods unlawfully introduced into the 
EU  and  dispatched  to  final  consumers  through  e-commerce.  In  addition,  OLAF  is  also 
active in identifying VAT registration hubs for shell companies that are used as fraudulent 
importers in VAT customs-related fraud schemes. Finally, since 2024, OLAF has launched 
investigations in relation to the evasion of import duties and VAT fraud related to imports 
from distant online platforms under the Import One Stop Shop. This includes extensive 

8  The  statistics  reported  by  the  Eurofisc  network  and  published  on  the  Commission  website 
(https://taxation-customs.ec.europa.eu/taxation/vat/vat-and-administrative-cooperation/eurofisc_en). 
MTIC is identified in TNA since 2020 and vehicles fraud as from 2023 

4 

 
 
 
cross-checking  of import and  VAT data using  advanced analytical  tools  to detect VAT 
evasion.  

The European Public Prosecutor’s Office is competent to investigate and prosecute cross-
border VAT fraud involving a total damage of at least EUR 10 million. In 2024, the EPPO 
opened investigations on cross-border VAT fraud for estimated damages  of EUR 13.15 
billion. Currently, there is no exchange of information between Eurofisc and the EPPO at 
EU level. The EPPO must rely on national channels to get the necessary information, which 
delays the transmission of  such information  and  complicates the process  of gathering  a 
complete dataset of evidence. A direct access at EU level to relevant VAT data on cross-
border transactions for the EPPO would streamline the gathering of evidence related 
to VAT fraud  and provide a single point of entry for any additional data on VAT 
fraud that is relevant for the EPPO’s investigations and prosecutions. Member States 
have expressed reluctance to share VAT data via Eurofisc without an explicit legal basis 
in Regulation (EU) No 904/2010.  

However, crucial VAT information exchanged under the EU framework is not accessible 
by these EU authorities and must be obtained through bilateral exchanges. This results in 
delays and fragmentation of data. It undermines the effectiveness of the fight against VAT 
fraud at EU level. At the same time, in March 20239 the Council stressed that increased 
levels  of  cooperation  between  police,  border  and  coast  guards,  customs,  judicial, 
administrative and tax authorities, as well as with EU institutions, bodies, agencies and 
relevant EU networks are crucial in the fight against criminal organisations. These criminal 
organisations are engaged in cross-border VAT fraud as a means of financing their other 
illicit activities.  In 2021, the Council10 agreed on the  EU priorities for the fight against 
serious  and  organised  crime  through  the  European  multi-disciplinary  platform  against 
criminal threats (EMPACT). VAT fraud is part of these priorities. Also, the ECA findings 
in several special reports on the VAT framework, shall be taken into due consideration11. 

This underscores the need to strengthen the multidisciplinary approach at EU level, which 
the EU framework for VAT administrative cooperation fails to effectively provide for as 
it stands. 

2.2.  Efficiency 

Member States have expressed satisfaction regarding the efficiency of the administrative 
cooperation  instruments12.  The  burden  of  complying  with  the  EU  framework  for  VAT 

9  Council conclusions on the permanent continuation of the EU Policy Cycle for organised and serious 

international crime: EMPACT 2022 + 
https://data.consilium.europa.eu/doc/document/ST-7100-2023-INIT/en/pdf 

10  Fight  against  organised  crime:  Council  sets  out  10  priorities 

for 

the  next  4  years 

https://www.consilium.europa.eu/en/press/press-releases/2021/05/26/fight-against-organised-crime-
council-sets-out-10-priorities-for-the-next-4-years/ 

11  Special  report  08/2025:  Value  Added  Tax  fraud  on  imports  –  The  EU’s  financial  interests  are 
insufficiently  protected  under  simplified  import  customs  procedures.  Special  report  12/2019:  “E-
commerce: many of the challenges of collecting VAT and customs duties remain to be resolved”. Special 
report  19/2017:  “Import  procedures:  shortcomings  in  the  legal  framework  and  an  ineffective 
implementation  impact  the  financial  interest  of  the  EU”.  Special  report  24/2015:  “Tackling  intra 
Community VAT fraud: More action needed”. Special report 13/2011: “Does the control of customs 
procedure 42 prevent and detect VAT evasion?” 

12 

It  should  be  noted  that  Member  States  cannot  always  provide  estimations  of  the  costs  of  VAT 
administrative cooperation. While 61% of MS consider that the benefits outweigh the costs, 25% of MS 
did not know. 

5 

 
 
administrative cooperation mostly lies with the tax authorities that implement cooperation 
mechanisms and coordinate their activities. The framework itself entails no direct costs for 
taxpayers or citizens. On the contrary, it aims to simplify access to information and reduce 
compliance costs that derive from the VAT Directive13 or national legislation. 

As  for  the  administrative  burden,  not  many  Member  States  have  been  able  to  offer  an 
accurate  estimation  of  the  costs  they  bear  in  terms  of  IT  or  human  resources  that  are 
necessary for the functioning of VAT administrative cooperation, but the few estimations 
provided did  not  exceed EUR 250 000 per year  for a system  like  VIES that  is  used  17 
million times by taxpayers every day for their invoicing. Without such a system, taxpayers 
would face much higher compliance costs as well as financial risks when supplying on the 
internal market. Central electronic systems such as Transaction Network analysis (TNA)14 
and Central Electronic System of Payment information (CESOP)15 are developed by the 
Commission  using  the Fiscalis  programme16, thus  avoiding the need to  develop  similar 
systems in all 27 Member States. TNA is a risk analysis tool exploiting VIES data on cross-
border  transactions;  it  allowed  Eurofisc  to  identify  EUR  14.6  billion  of  suspicious 
transactions and resulted in 2 352 VAT deregistrations in 2023, saving billions of euros of 
VAT  revenues.  CESOP  collects  data  on  cross-border  payments  and  allows  Eurofisc  to 
cross-check  VAT  data  with  data  on  payees  to  facilitate  detection  of  VAT  fraud  in  e-
commerce. For other systems, the Commission ensures that systems developed at national 
level  are  interoperable,  saving  costs  for  all  Member  States.  In  this  respect,  the  benefits 
outweigh the costs significantly. 

At the same time, the evaluation points out that there are overlaps between the cooperation 
tools. Some reporting obligations could be lifted to alleviate administrative burden for tax 
administrations  and  taxpayers  as  the  information  is  no  longer  relevant  or  available 
somewhere else. 

2.3.  Coherence 

internal  coherence, 

On the coherence of the EU framework, the assessment considers both internal and external 
aspects.  As  regards 
identified  any 
inconsistencies between the provisions within the Council Regulation (EU) No 904/2010 
and  the  interaction  of  the  different  cooperation  tools,  despite  repeated  and  frequent 
amendments. Member States appreciate the variety of tools, and the majority do not report 
any conflicts between them even if they overlap in some cases. Member States choose the 
right tool for their needs.  

the  evaluation  has  not 

13  Council Directive 2006/112/EC of 28 November 2006 on the common system of value added tax OJ L 

347, 11.12.2006 

14  Transaction Network Analysis is an electronic system developed and maintained by the Commission to 
assist Eurofisc with data collection and analysis. Its exact functioning is sensitive but, in general terms, 
TNA helps Eurofisc to visualise the interconnections of companies in the fraud scheme and the scale of 
VAT at risk. The Commission does not have access to the data.  

15  CESOP is the new electronic system in the fight against VAT fraud in the e-commerce sector. It was 
introduced in January 2024. It receives data on cross-border payments from payment services providers 
and compares it with VAT reporting. The aim is to identify under- or not reporting companies. It is also 
developed and maintained by the Commission without a direct access to the data processed. 

16  Regulation (EU) 2021/847 establishing the ‘Fiscalis’ programme for cooperation in the field of taxation 

and repealing Regulation (EU) No 1286/2013 

6 

 
 
When it comes to external coherence, there is no overlap between Council Regulation (EU) 
No  904/2010  and  other  EU  legislation  such  as  the  VAT  Directive,  the  Directive  on 
administrative  cooperation  in  the  field  of  taxation17  or  the  Directive  concerning  mutual 
assistance for the recovery of claims18; they are rather complementary. Indeed, improving 
administrative cooperation in the field of VAT is fully coherent with other EU policies in 
the field of VAT. However, the lack of legal provision within Council Regulation (EU) No 
904/2010, suited to facilitate real and effective VAT cooperation at EU level between tax 
authorities  participating  in  Eurofisc  and  other  investigative  bodies/agencies  such  as  the 
EPPO, OLAF and Europol, could be perceived as an inconsistency. In addition, in the case 
of OLAF, this is not in line with the provisions of Council Regulation (EC) No 515/9719, 
which deals with administrative cooperation in the field of customs law, as customs fraud 
is inextricably linked to evasion of VAT at import and possibly also to evasion of intra-
EU  VAT.  While  the  need  for  cooperation  between  all  these  authorities  is  widely 
recognised, the exchanges are inexistent in practice or do not have an explicit legal base. 
In  particular,  the  fact  that  the  EPPO  is  not  being  granted  direct  access  at  EU  level  to 
relevant VAT data on cross-border transactions and that OLAF has limited possibilities to 
cooperate with Eurofisc and Member States, as well as impracticalities related to Europol 
collaboration, undermine their potential to contribute more effectively to the fight against 
VAT fraud. These problems are particularly relevant as tax competences belong primarily 
to the Member States and are highly politically sensitive while Eurofisc has neither legal 
personality nor hierarchical structure. 

2.4.  EU added value 

Without  the EU framework for  VAT  administrative cooperation, Member States would 
need to rely on bilateral or multilateral agreements as cross-border transactions would still 
require joint control by tax administrations.  Absence of an EU  framework  would mean 
additional  costs  to  build  national  electronic  systems  and  make  them  interoperable  with 
other countries.  

Moreover,  the  fight  against  VAT  fraud  on  cross-border  transactions  requires  close 
cooperation  of  all  Member  States  in  order  to  have  a  lasting  impact.  National  or  even 
regional approaches would not be effective. Fraudsters would exploit the weakness of such 
a network by positioning themselves in the country that cooperates the least.  

Finally,  the  costs  of  conducting  business  in  the  EU  would  also  increase  if  the  EU 
framework did not exist. It is an advantage for taxpayers to be able to check the validity of 
all EU VAT numbers through one single website and avoids having to build 27 interfaces 
with national databases. 

2.5.  Relevance 

The  EU  framework  for  VAT  administrative  cooperation  remains  relevant  as  the  rules 
governing cross-border transactions remain unchanged and fraudsters continue to exploit 

17  Council Directive 2011/16/EU of 15 February 2011 on administrative cooperation in the field of taxation 

and repealing Directive 77/799/EEC. 

18  Council  Directive  2010/24/EU  of  16  March  2010  concerning  mutual  assistance  for  the  recovery  of 

claims relating to taxes, duties and other measures. 

19  Council Regulation (EC) No 515/97 of 13 March 1997 on mutual assistance between the administrative 
authorities of the Member States and cooperation between the latter and the Commission to ensure the 
correct application of the law on customs and agricultural matters. 

7 

 
 
the weakness of these rules. The MTIC gap study mentioned in the introduction estimates 
that  fraudsters  continue  to  exploit  the  transitional  VAT  system  for  cross-border 
transactions,  thus  depriving  Member  States  from  significant  amounts  of  revenues.  The 
VAT  gap  continues  to  decline,  which  shows  that  national  VAT  fraud  is  decreasing. 
However, Member States still strongly perceive the threat from cross-border VAT fraud 
schemes. Eurofisc remains the most effective administrative means to tackle this kind of 
fraud, thus proving the relevance of the EU framework. 

3.  CONCLUSIONS  ON  THE  FUNCTIONING  OF  THE  EU  FRAMEWORK  FOR  VAT 

ADMINISTRATIVE COOPERATION 

The  overall  findings  of  the  evaluation  suggest  that  the  EU  framework  for  VAT 
administrative cooperation is largely effective in ensuring that tax administrations have all 
the  necessary  means  at  their  disposal  to  control  cross-border  transactions  for  VAT 
purposes. The cooperation between Member States aims at reducing administrative burden 
for tax experts and render controls more efficient. The EU framework remains relevant and 
coherent, but its external coherence must be revisited to better fit into the multidisciplinary 
approach in  the  fight  against VAT fraud.  At the same time, the  EU added value of the 
framework is clear to tax administrations and taxpayers.  

The EU framework largely fulfils its objectives, even though the effectiveness of the multi-
disciplinary approach in the fight against VAT fraud remains an issue. Member States rely 
heavily  on  different  means  of  cooperation  to  control  the  growing  number  of  intra-EU 
transactions. However, the sheer number of cross-border transactions has forced Member 
States to rely more on VIES, which allows them to obtain the information in an automated 
way in combination with Eurofisc to quickly verify suspicions of fraud. Other means of 
cooperation are left to less urgent cases. This was confirmed by tax administrations that 
were consulted during the evaluation. 

The joint risk analysis of VAT data is provided by Eurofisc. Eurofisc identified EUR 49.8 
billion worth of suspicious  transactions between  2020 and 2024.  This  amount  could  be 
even bigger if Eurofisc had access to other sources of information that are not currently 
available  in  the  EU  framework  for  VAT  administrative  cooperation  but  are  usually 
available to tax administrations at national level. It would be beneficial for the fight against 
VAT fraud to extend the list of data that Eurofisc can process. For example, by accessing 
data on beneficiary ownerships, Eurofisc could counter the use of strawmen in VAT fraud. 
Access  to  bank  registers  and  regular  contacts  with  anti-money  laundering  authorities 
(Financial Investigation Units20) would allow authorities to better apply the ’follow-the-
money’ principle in the fight against fraud.  

The main conclusion is that while Union legislation on VAT administrative cooperation is 
providing a robust and well-functioning framework for close cooperation between relevant 
authorities, VAT fraud remains an important financial threat to national and EU budgets. 
Moreover, serious VAT fraud also endangers the security of the EU, as recognised by the 

20  Directive  (EU)  2024/1640  of  the  European  Parliament  and  of  the  Council  of  31  May  2024  on  the 
mechanisms to be put in place by Member States for the prevention of the use of the financial system 
for the purposes of money laundering or terrorist financing. 

8 

 
 
 
Council, since organised crime groups often use their fraudulent VAT profits to fund other 
forms of crimes, such as cigarette smuggling or drug trafficking. 

Against  this  background,  the  following  major  areas  in  VAT  administrative  cooperation 
have been identified where VAT fraud could be reduced even further:  

•  streamlining Eurofisc’s capacity to identify VAT fraud and act as an early warning 

• 

mechanism to stop fraud with administrative measures; 
intensifying  the  cooperation  between  tax  and  customs  authorities  in  the  fight 
against  VAT  fraud  at  import,  providing  for  a  framework  of  administrative 
cooperation  between  OLAF,  Eurofisc  and  national  customs  and  tax  authorities, 
including direct access to relevant data; this has been noted also by the ECA in its 
special reports No 24/2015 and No 8/2025;21 

•  enhancing  multidisciplinary  cooperation  at  EU 

level  between  various 
administrations such as OLAF, law enforcement and prosecution authorities, such 
as Europol and the EPPO, including direct access at EU level to relevant data in 
accordance  with  their  respective  mandate  taking  into  consideration  the  relevant 
data protection and procedural safeguards. 

4.  WAY FORWARD 

To address the points of interest listed above, the Commission will consider an amendment 
of  the  EU  framework  for  VAT  administrative  cooperation  focusing  on  the  multi-
disciplinary aspects of fighting against VAT fraud in line with the ongoing review of the 
EU Anti-Fraud Architecture22.  

4.1.  Reinforcement of Eurofisc 

In the past years, Eurofisc was seen by Member States as an effective administrative tool 
in the fight against cross-border VAT fraud. It has privileged access to VAT information 
and is equipped with effective risk analysis tools, with automated data collection and pre-
analysis,  that  highly  improved  its  functioning.  Member  States  also  recognise  the  added 
value of Eurofisc and its role in fighting VAT fraud. To take advantage of this potential, 
the Commission will explore: 

1.  whether Eurofisc governance and accountability shall be strengthened; 
2.  whether  Eurofisc  might  benefit  from  additional  information,  such  as  bank 
account registers, company ownership data or money laundering information 
(FIUs), to identify the people behind the fraud and their financial assets;  

3.  how to ensure that Eurofisc signals are followed up with timely administrative 
measures  to  stop  the  fraud,  such  as  fast  invalidation  of  VAT  numbers,  that 
would shorten the time a fraudster can act. 

21   See  Recommendation  12  of  Special  report  24/2015:  “Tackling  intra  Community  VAT  fraud:  More 
action  needed”  and  paragraphs  93  and  107  of  Special  report  08/2025:  “Value  Added  Tax  fraud  on 
imports  -  The  EU’s  financial  interests  are  insufficiently  protected  under  simplified  import  customs 
procedures”. 

22  Review of the overall anti-fraud architecture linked to the EU’s financial interests, ensuring an effective 
and  efficient  cooperation  with  the  European  Public  Prosecutor’s  Office  to  protect  the  EU  budget. 
https://commission.europa.eu/about/organisation/college-commissioners/piotr-serafin_en 

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4.2.  Reinforcement  of  the  multi-disciplinary  approach  in  the  fight  against 

VAT fraud 

The EU framework for VAT administrative cooperation could be further opened to access 
from other authorities within the remit of their mandate in the field of fighting VAT fraud, 
in  particular  carousel  fraud.  This  is  particularly  pressing  for  the  EPPO  with  numerous 
investigations related to cross-border VAT fraud. A direct access to VAT databases at 
EU level, such as VIES or CESOP, would shorten considerably its data collection work. 
This would be equally important for OLAF in its pursuit of administrative investigations 
of customs fraud and for steering cooperation between customs and VAT authorities and 
Eurofisc. 

Reinforcing the multi-disciplinary approach in the fight against VAT fraud is one of the 
specific  objectives  of  the  EU  framework  for  VAT  administrative  cooperation.  The 
evaluation demonstrates that the framework has failed in this regard as it provides for very 
limited cooperation of Eurofisc with OLAF and Europol. The Commission will consider 
reshaping  this  part  of  the  framework  and  assess  solutions,  including  direct  access  to 
information exchanged under the EU framework, that would be in line with the mandate 
and needs of these authorities. 

The Commission will explore: 

1.  Ways to strengthen the overall EU administrative cooperation framework to support a 

more effective multi-disciplinary approach in the fight against VAT fraud;  

2.  In the short term, options to ensure the consistency of  the EPPO Regulation23 and the 
OLAF  Regulation24  with  the  EU  Framework  for  VAT  administrative  cooperation, 
including possibilities for direct access by the EPPO and OLAF to VAT data on cross-
border transactions, taking into consideration the relevant data protection safeguards; 

3.  In a broader and subsequent step, the possibility of a comprehensive review of Council 
Regulation (EU) No 904/2010 to allow the sharing of relevant information with all EU 
anti-fraud authorities including customs and Europol within their respective mandates.  

23  Council  Regulation (EU) 2017/1939 of  12  October  2017  implementing  enhanced  cooperation  on  the 

establishment of the European Public Prosecutor's Office. 

24  Regulation (EU, Euratom) No 883/2013 of the European Parliament and of the Council of 11 September 
2013 concerning investigations conducted by the European Anti-Fraud Office (OLAF) and repealing 
Regulation (EC) No 1073/1999 of the European Parliament and of the Council and Council Regulation 
(Euratom) No 1074/1999. 

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