COMMISSION STAFF WORKING DOCUMENT […] Accompanying the document REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS on the interim evaluation of the Fiscalis programme for cooperation in the field of taxation for 2021-2027
Date: 2026-01-23
Institutions: Directorate-General for Taxation and Customs Union, European Commission
Subjects: EU programme, European tax cooperation, administrative cooperation, exchange of information, information system, project evaluation, tax avoidance, tax law, tax offence, vocational training

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 23.1.2026  SWD(2026) 9 final  COMMISSION STAFF WORKING DOCUMENT […] Accompanying the document REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS  on the interim evaluation of the Fiscalis programme for cooperation in the field of taxation for 2021-2027 {COM(2026) 18 final}  
 
 
Table of Contents 

1. 

INTRODUCTION ................................................................................................................... 3 

1.1  Purpose and scope of the evaluation .......................................................................... 3 

2.  WHAT WAS THE EXPECTED OUTCOME OF THE INTERVENTION?.......................... 6 

2.1  Description of the intervention and its objectives ...................................................... 6 

2.2.  Point(s) of comparison ............................................................................................... 9 

3.  HOW HAS THE SITUATION EVOLVED OVER THE EVALUATION PERIOD? ......... 10 

3.1  Current state of play ................................................................................................. 10 

4.  EVALUATION FINDINGS (ANALYTICAL PART) ......................................................... 19 

4.1  To what extent was the intervention successful and why? ...................................... 22 

Effectiveness .................................................................................................................... 22 

Efficiency ......................................................................................................................... 29 

Coherence ....................................................................................................................... 36 

4.2.  How did the EU intervention make a difference and to whom? (EU added value)..40 

4.3.  Is the intervention still relevant? (Relevance) .......................................................... 45 

5.  WHAT ARE THE CONCLUSIONS AND LESSONS LEARNED? ................................... 49 

5.1.  Main achievements and strengths of the Fiscalis programme ................................. 49 

5.2.  Lessons learned and areas for improvement.............................................................. 51 

ANNEX I:  PROCEDURAL INFORMATION ............................................................................. 55 

ANNEX II. METHODOLOGY AND ANALYTICAL MODELS USED .................................... 58 

ANNEX III. EVALUATION MATRIX ........................................................................................ 67 

ANNEX IV. OVERVIEW OF BENEFITS AND COSTS ............................................................. 82 

ANNEX V. STAKEHOLDERS CONSULTATION - SYNOPSIS REPORT ............................... 84 

1 

 
 
 
 
 
 
Glossary 

Term or acronym  Meaning or definition 
AEOI 
ART 
B2B 
CBA 
CBAM 
CCN 
CCN2 
CESOP 
CIT 
CLEP 
CPMT 
CSI 
CTA 
DAC 
DATANA 
DG TAXUD 
EC 
EMCS 
EES 
eFCA 
EMCS 
FATCA 
LMS 
LTI 
MANITC V 
MASP-T 
MAWP 
MEF 
MFF 
MOSS 
MS 
MTIC 
NFCs 
NPC 
OLAF 
PAOEs 
PIT 
SEED 
SME 
SOA 
TEDB 
TES 
TNA 
TSG 
TSS 
VAT 
VIES 
VISDAC 
VoW 

Automatic exchange of information 
Activity reporting tool 
Business-to-business 
Cost-benefit analysis 
Carbon Border Adjustment Mechanism 
Common Communication Network 
Common Communication Network 2 
Central Electronic System of Payment Information 
Corporate income tax 
Common learning event programme 
Commission programme management team 
Common Systems Interface  
Conformance testing application 
Directive on Administrative Cooperation 
Development of data analysis tool 
Directorate-General for Taxation and Customs Union 
European Commission 
Excise Movement and Control System 
European electronic systems 
eForms Central Application 
Excise Movement and Control System 
Foreign Account Tax Compliance Act 
Learning Management System 
Learning Tools Interoperability 
Managed IT collaboration expert team 
Multiannual strategic plan for taxation  
Multiannual work programme  
Monitoring and evaluation framework 
Multiannual financial framework 
Mini One-Stop Shop  
Member State(s) 
Missing trader intra-community 
National Fiscalis coordinators 
National programme coordinators 
European Anti-Fraud Office  
Presence in administrative offices and participation in administrative enquiries 
Personal income tax 
System for the exchange of excise data 
Small and medium-sized enterprise(s) 
Service-oriented architecture 
Taxes in Europe Database 
trans-European systems 
Transaction Network Analysis 
Training Support Group 
Taxation Statistical System 
Value added tax 
VAT Information Exchange System 
Visits to Member States Directive on Administrative Cooperation 
VIES-on-the-Web 

2 

 
1. 

INTRODUCTION 

This  staff  working  document  (SWD)  reports  on  the  interim  evaluation  of  the  Fiscalis  programme 
(hereafter:  ‘the  programme’).  The  programme  is  one  of  the  principal  tools  used  to  support  the 
implementation  of  European  Union  taxation  policy.  The  programme  provides  a  framework  for 
improving  the  functioning  of  the  taxation  systems  in  the  single  market  by  increasing  cooperation 
between  participating  countries,  their  tax  authorities  and  officials.  By  ensuring  the  exchange  of 
increasing  participating  countries’ 
information,  supporting  administrative  cooperation  and 
administrative capacity, the programme supports: (i) the implementation of EU law in the field of 
taxation; and (ii) the fight against tax fraud, tax evasion and aggressive tax planning. The programme's 
main beneficiaries are the EU Member States' tax administrations and its budget of EUR 269 million 
for  the  period  2021-2027  supports  three  main  types  of  activities,  namely:  (i)  EESs,  which  have 
accounted  for  over  80%  of  the  budget  so  far;  (ii)  actions  fostering  collaboration  among  tax 
administrations; and (iii) capacity-building actions. 

The Fiscalis programme was set up by Regulation (EU) No 2021/847 of the European Parliament and 
of the Council of 20 May 2021 establishing an action programme to improve the operation of taxation 
systems  in  the  European  Union.  In  line  with  Article  15(2)  of  the  Regulation  establishing  the 
programme, the Commission must carry out an interim evaluation no later than four years after the 
implementation of the programme is launched and must communicate the conclusions of the interim 
[…and final] evaluations, including  its observations, to  the European Parliament,  the Council, the 
European Economic and Social Committee and to the Committee of the Regions.  

1.1 Purpose and scope of the evaluation 

Building on previous assessments, this evaluation focuses on the common components of the EESs 
in the area of taxation, which account for most of the total budget allocated to the Fiscalis programme. 
To a certain but lesser extent, the evaluation also covers the programme’s other core activities, 
namely: (i) collaborative actions (which provide a platform for tax officials and other stakeholders to 
cooperate  and  ensure,  for  example,  uniform  implementation  of  EU  tax  law);  (ii)  expert  teams  (a 
relatively new bottom-up activity allowing the Member States to jointly develop specific initiatives); 
and (iii) human capacity building. Since most of these activities were evaluated previously and have 
been  relatively  stable  over  the  years,  the  evaluation  focuses  on  aspects  that  have  recently  been 
introduced or have undergone recent changes. In this vein, when it comes to collaborative activities, 
the evaluation also assesses the programme’s new monitoring and evaluation framework (MEF) and 
takes into consideration follow-up measures arising from the evaluation of the previous iteration of 
the programme.  

The  purpose  of  the  evaluation  is  to  assess  the  Fiscalis  programme’s  progress  towards  its  main 
objectives  between  2021  and  2024,  in  terms  of  the  five  better  regulation  criteria  of  effectiveness, 
efficiency (with a focus on costs and benefits), coherence, relevance and EU added value1.  

1 This evaluation follows and fulfils the Commission’s better regulation requirements as updated in July 2023. See ‘Better 

regulation’ guidelines (2021) and toolbox (2023): Better regulation: guidelines and toolbox. 

3 

 
 
 
 
Under the overall criterion of effectiveness, the evaluation examines first to what extent the Fiscalis 
programme has been successful over the relevant period, and then, the possible reasons behind that. 
The evaluation does this by focusing on the implementation and achievements of the different types 
of  activities  and  their  relative  contribution  to  the  programme’s  objectives.  The  efficiency  of  the 
Fiscalis  programme  is  evaluated  by  looking  at  the  costs  and  benefits  of  the  EESs  and  their 
components, and the administrative burden for tax authorities and economic operators. The evaluation 
then  investigates  the  efficiency  of  the  non-EES  components,  including  training  activities, 
collaborative actions, the learning management system/platform, e-learning, and common learning 
events. At this stage (i.e. halfway through the funding period) this will shed light on the extent to 
which the programme’s budget (EUR 269 million between 2021 and 2027) has been spent efficiently 
on the activities that it supports. The analysis also looks at the efficiency of the overall programme 
management and governance.  

The assessment of relevance covers two main aspects, namely: (i) the alignment of the programme’s 
objectives with the EU's needs and challenges in the field of taxation; and (ii) the appropriateness and 
fitness for purpose of the programme's features and set-up, specifically as regards its support for the 
common  components  of  the  EESs  and  for  collaborative  activities,  training  and  other  actions.  The 
analysis  of  coherence  will  look  at  the  extent  to  which  the  programme  is  coherent  with  other  EU 
initiatives/programmes with similar objectives, and at the internal consistency of the actions funded 
by  the  programme  itself.  Thus,  the  evaluation  will  report  on  the  implementation  of  the 
recommendations  regarding  the  Fiscalis  programme's  consistency  with  the  Union  anti-fraud 
programme2, and its alignment with measures such as the instrument for  pre-accession assistance 
(IPA) and the instrument for technical assistance and information exchange (TAIEX) among others.  

Lastly, the evaluation will examine the criterion of EU added value to report on the extent to which 
the programme has brought about changes beyond those which could have been expected as a result 
of national actions by the Member States acting alone. This aspect is assessed by looking at both the 
EU added value of the different types of activities funded by  the programme (i.e. IT systems, the 
Customs & Tax EU Learning Portal, expert teams and collaborative actions) and the programme's 
overall added value.  

The overall evaluation methodology3 consisted of three main phases: (i) a structuring phase, which 
included  preparatory  activities  for  designing  and  developing  the  evaluation,  such  as  selecting  an 
external  contractor  and  identifying  relevant  stakeholders  to  be  consulted;  (ii)  data  collection  and 
analysis, involving stakeholder consultations, legal and desk research, and analytical work to support 
the assessment;  and (iii) evaluation  and insights, where the information  collected was analysed to 
produce  the  evaluation  report  by  examining  the  five  better  regulation  criteria  and  subsequently 
drawing conclusions and lessons learned.  

This evaluation is primarily based on the findings of an external study carried out over a 12-month 
period by a consortium led by Economisti Associati4. In order to devise a suitable approach to the 
evaluation,  some  critical  elements  had  to  be  accounted  for  at  the  outset  of  the  exercise.  These 

2 Union anti-fraud programme (UAFP) - European Commission. 
3 Further details on the evaluation methodology are provided in Annex II. 
4 Link study. It is not published yet. 

4 

 
 
 
include:  (i)  the  programme's  gradual  development,  whereby  its  key  types  of  activities  have  been 
developed and improved over time, while remaining broadly stable; (ii) the budgetary split, whereby 
most  of  the  programme's  resources  are  devoted  to  a  number  of  IT  systems  (EESs)  in  the  field  of 
taxation; (iii) the fact that collaborative activities and human capacity-building actions have already 
been  extensively  evaluated;  (iv)  the  difficulties  faced  by  previous  evaluations,  particularly  in 
measuring  the  IT  systems'  costs  and  benefits,  and  dealing  with  ‘consultation  fatigue’  among  core 
stakeholders; and (v) the recent launch of the MEF, which provides a more solid base for monitoring 
data than has been available for past evaluations. This led to an approach that relies heavily on case 
studies to investigate as deeply as possible the issues that are of most interest, while dedicating less 
time  and  effort  to  assessing  all  the  programme’s  components  (since  previous  evaluations  have 
covered this quite exhaustively)5.  

Data  for  both  the  case  studies  and  the  programme-level  assessment  was  collected  via  three  main 
methods:  (i)  desk  research  to  review  a  wide  range  of  relevant  sources  of  secondary  data  and 
information; (ii) 84 interviews with representatives of national tax authorities, economic operators 
and the European Commission; and (iii) three separate targeted surveys, namely one for NFCs in 
the  national  tax  authorities  of  participating  countries  (27  respondents),  and  two  short  online  user 
surveys as part of two of the case studies (on VIES-on-the-web (1 248 respondents) and the LMS (62 
respondents)).  

5 The most recent evaluations of the programme were the mid-term and final evaluations of the Fiscalis 2020 

programme and can be found on the Commission’s website at the links provided. 

5 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
2.  WHAT WAS THE EXPECTED OUTCOME OF THE INTERVENTION? 

The  predecessor  to  the  current  Fiscalis  programme  (Fiscalis  2020)  ran  from  2014  to  2020.  The 
findings  of  the  final  evaluation,  published  in  2022,  indicate  that  the  programme  was  broadly 
successful in achieving its objectives6. The evaluation recognised that some limitations had affected 
the  analysis,  but  concluded  that  Fiscalis  2020  had  delivered  efficient  and  effective  results  for  tax 
authorities and businesses. There are examples that illustrate that specific activities carried out under 
Fiscalis  2020,  such  as  data  sharing  through  the  DAC1  and  DAC2  systems,  simplified  both 
communication  between  authorities  and  compliance  with  tax  rules.  Feedback  gathered  through 
consultations also indicated that Fiscalis 2020 activities were perceived as useful by key stakeholders 
and  as  having  had  an  impact  on  their  organisations’  working  practices7.  Specific  initiatives  also 
provided evidence of the programme's value added, such as the development of the TNA system and 
the excise duty calculator, which ‘might not have existed if Fiscalis 2020 did not provide funding for 
expert teams’8. 

2.1  Description of the intervention and its objectives 

The  current  Fiscalis  programme  (for  2021-2027)  aligns  with  the  original  objective  of  improving 
cooperation  among  tax  authorities.  In  the  proposal  for  the  2021-2027  Fiscalis  programme,  the 
Commission recognised the successes of previous Fiscalis programmes, while acknowledging that 
more  progress  should  be  made  in  fostering  cooperation  among  tax  authorities9.  The  resulting 
Regulation (adopted by the Council and the Parliament following the agreement on the MFF for 2021-
2027) allocates EUR 269 million in current prices to the Fiscalis programme, up from EUR 223.2 
million  in  the  2014-2020  period10.  In  addition  to  the  EU  Member  States,  participation  in  the 
programme (and in  

some but not all of its activities and IT systems) is open to candidate and potential candidate countries, 
with a view both to fostering convergence and supporting the programme's objectives. 

The intervention logic of the programme hinges on three general objectives, namely: 

•  supporting  tax  authorities  and  taxation  in  order  to  improve  the  functioning  of  the  internal 

market; 
fostering the competitiveness of the EU and fair competition in the EU; and 

• 
•  protecting  (including  from  tax  fraud,  tax  evasion  and  tax  avoidance)  the  financial  and 

economic interests of the EU and its Member States. 

In turn, these general objectives are reflected in three specific objectives, which comprise: 

6 SWD (2022) 406 final 
7 Study on the final evaluation of the Fiscalis 2020 programme. 
8  European  Commission  (2021).  Study  on  the  final  evaluation  of  the  Fiscalis  2020  programme.  Available  at: 

https://op.europa.eu/en/publication-detail/-/publication/d7be4130-7f4e-11ed-9887-01aa75ed71a1/language-en. 

9 COM (2018) 443 final. 
10 European Parliament (2024). Establishing the ‘Fiscalis’ programme for cooperation in the field of taxation. Available at: 

https://www.europarl.europa.eu/legislative-train/theme-new-boost-for-jobs-growth-and-investment/file-mff-fiscalis-
programme-for-cooperation-in-the-field-of-taxation. 

6 

 
 
 
 
 
•  supporting  administrative  capacity  building,  including  skills  and  the  development  and 

operation of EESs; 
fostering cooperation between tax authorities, including the exchange of tax information; and 

• 
•  supporting tax policy and the implementation of EU law relating to taxation. 

The activities of the Fiscalis programme are categorised in three main areas. 

•  EESs  received  84%  of  the  Fiscalis  budget  between  2021  and  202411  for  developing, 
maintaining and improving EESs to boost coordination and information sharing. The primary 
aim of the EESs is to help implement EU tax legislation properly and to support tax authorities 
in performing their tasks. 

•  Collaboration  actions,  including  expert  teams,  provide  a  platform  for  tax  authorities  to 
share  their  knowledge,  experience  and  good  practices,  and  to  jointly  develop  operational 
guidelines.  This  is  achieved  by  supporting  the  setting  up  of  meetings  and  project-based 
collaboration.  In  most  cases,  the  support  consists  of  costs  for  travel,  accommodation  and 
subsistence, while salary costs can also be covered for certain actions.  

•  Capacity  building  and  human  competency  aims  to  improve  performance  across  EU  tax 
authorities.  Fiscalis  supports  capacity  building  through  e-learning,  workshops  and  training 
sessions, ensuring that tax officials are equipped to manage modern taxation challenges. This 
includes  the  development  of  a  dedicated  online  portal,  the  Customs  &  Tax  EU  Learning 
Portal12. 

Figure 1. Fiscalis programme intervention logic 

Source: MEF 

11 Based on the budget allocation from the annual progress reports for 2021 to 2024. 
12 https://customs-taxation.learning.europa.eu. 

7 

 
 
 
 
 
Several inputs underpin these activities, including financial resources (i.e. the programme budget) 
that are used to: (i) obtain (primarily IT-related) services via public procurement; and (ii) provide 
grants  to  enable  stakeholders  (mainly  national  tax  administrations)  to  participate  in  the  activities. 
Human  resources  from  both  the  European  Commission  and  national  levels  are  essential.  The 
multiannual  work  programmes  (MAWP)  (of  which  two  have  been  produced  so  far,  and  the 
multiannual strategic planning for taxation (MASP-T) provide direction for the programme.  

While  the  form  of  the  programme  has  been  broadly  stable  across  funding  periods,  the  current 
programme has some new features. The first new feature concerns the introduction of the MASP-T, 
which  sets  out  a  strategic  framework  and  milestones  for  managing  the  IT  projects  funded  by  the 
programme13. Another new feature is the way in which collaborative activities are managed, with the 
Commission  no  longer  disbursing  funding  directly,  but  now  awarding  grants  to  a  consortium 
comprising tax administrations from participating countries. Lastly, dedicated ‘innovation activities’, 
such as proof of concept, pilot projects and prototypes, can be funded under the Fiscalis Regulation.  

The  European  Commission  (DG  TAXUD)  is  responsible  for  implementing  Fiscalis  under  direct 
management14. The programme is implemented on the basis of programming cycles in the form of 
MAWPs, which represent the programme’s operational and financial framework. Two MAWPs (for 
2021-2023 and for 2024-2025) have been produced so far. The Commission programme management 
team (CPMT), which is part of DG TAXUD, ensures the strategic and overall management of the 
Fiscalis programme, as well as providing oversight. The CPMT operates with the help of the Fiscalis 
programme committee and national programme coordinators (NPCs) and their teams. The Fiscalis 
committee  was  set  up  under  Article  18  of  the  Regulation  and  is  composed  of  delegates  from  all 
participating countries. It plays a formal role in the programme's governance and decision-making 
process, particularly concerning the legal endorsement of strategic documents, such as the MAWPs. 
In contrast, the NPCs come together in a Commission expert group15, which also forms one of the 
programme’s collaborative actions (see description of the actions below). The NPCs are designated 
by each participating country and have a more operational function, involving the coordination and 
day-to-day implementation of the programme, including the planning and monitoring of actions at 
national level. The management arrangements for the different types of actions are as follows.  

•  For the EESs, DG TAXUD retains coordination functions, and develops and operates the EU 
components of the systems, while (where relevant) the Member States develop and operate 
national components.  

•  Collaborative actions are conducted via grant agreements with participating administrations, 
represented by a grant coordinator (currently the Latvian tax authority for the collaborative 
activities grant). Both the programme beneficiary countries and the Commission can initiate, 
chair  and  lead  such  collaborative  activities.  Collaborative  activities  fall  into  two  broad 

13 MASP-T - European Commission. 
14 As described in the ‘Fiscalis Programme Operational Guide’, which provides operational information on the programme 
actions, including practical implementation of the collaborative actions: meetings and similar ad hoc events, as well 
as project-based collaboration activities, including expert teams. 

15 More information on the expert group on Fiscalis programme management can be found on the register of Commission 

expert groups and other similar entities. 

8 

 
 
 
categories: meetings / ad hoc events (which tend to be one-off) and structured project-based 
collaborations, such as project groups. Collaborative actions also include a specialised type of 
activity called expert teams, which involve increased cooperation and operate under specific 
grant agreements. Unlike in the case of other collaborative actions, expert teams can benefit 
from programme funding for participants' staff/salary costs.  

•  The capacity-building actions are overseen by the CPMT with the support of the Training 
Support  Group  (TSG),  which  is  a  project  group  involving  all  participating  countries.  DG 
TAXUD  manages  certain  capacity-building  actions  directly,  such  as  the  above-mentioned 
portal,  and  the  development  of  e-learning  modules.  Other  activities,  such  as  IT  capacity-
building events, are organised in the same way as collaborative actions.  

2.2. Point(s) of comparison  

The first version of the Fiscalis programme was launched in 1998 and has been followed without 
interruption by subsequent versions since then. Therefore, it is rather limiting to compare the situation 
under  the  current  programme  with  a  hypothetical  scenario  where  no  Fiscalis  programme  exists. 
Subsequent versions of the programme have created a baseline of cooperation in the field of taxation 
and  have  evolved  gradually  to  address  new  and  emerging  challenges  and  priorities.  Therefore, 
comparing  the  developments  in  the  last  few  years  with  the  situation  before  1998,  or  imagining  a 
sudden disappearance of the entire programme would not be overly instructive.  

Relevant information that can act as a sort of ‘baseline’ can be draw from the final evaluation of 
Fiscalis 202016, which concluded that the programme had been effective in achieving its objectives 
and would probably continue to be a relevant tool at EU level for achieving the goals of supporting 
the implementation of EU tax legislation and the fight against tax fraud, tax evasion and aggressive 
tax planning. The final evaluation of Fiscalis 2020 also identified some areas where there is room for 
improvement, such as weak evidence on the costs and benefits of the IT systems, and the need for 
non-EU countries to be able to participate in a wider set of activities. 

Both  assessments  provide  indications  that  can  be  used  to:  (i)  contextualise  and  compare  the 
performance of the current programme with that of its predecessor; and (ii) assess to what extent 
the conclusions of the previous evaluation continue to be valid, and whether the weaknesses identified 
have been effectively addressed. 

In addition to this, the following aspects also provide relevant points of comparison. 

   An MEF for the current  programme has been developed, and DG TAXUD has set targets and 
collected data for the relevant indicators since the inception of the programme. Where possible 
and appropriate, the evaluation considers how these indicators have developed over time, from 
the ‘baseline’ in 2021 until 2024. 

   The reliance on in-depth case studies to assess the effectiveness (including the costs and benefits 
of selected IT systems) is a key element of the methodology for this evaluation. To facilitate a 
robust analysis, each case study developed a counterfactual to consider what would have been 

16 European Commission (2022): Final evaluation of the Fiscalis 2020 programme, COM (2022) 717 final. 

9 

 
 
 
 
the  likely  situation  in  the  absence  of  Fiscalis  funding  for  the  systems  in  question.  These 
counterfactuals provided the point of comparison for the estimation of the costs and benefits of 
(Fiscalis programme support for) each of the systems.  

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

3.1 Current state of play 

The current Fiscalis programme (2021-2027), which has a budget of EUR 269 million reflecting 
recent  EU  policy  developments,  continues  to  pursue  its  original  goal  of  improving  cooperation 
between tax authorities. The programme's budget supports the expansion and modernisation of IT 
systems in the tax area to meet the growing need for more sophisticated digital tools. Guided by the 
2021-2023  and  2024-2025  MAWPs,  which  outline  the  priorities  and  actions  for  each  period,  the 
programme focuses on key components, such as developing and implementing EESs, establishing 
expert teams and improving capacity building within tax administrations across the EU. 

The MAWPs provide a clear roadmap for the Fiscalis programme by identifying priority actions that 
address  the  changing  needs  of  tax  administrations  in  the  context  of  cross-border  cooperation, 
digitalisation  and  tax  compliance.  Each  of  the  programme’s  components  is  designed  to  foster 
collaboration, improve operational efficiency and build the necessary expertise to meet current and 
future tax challenges.  

After the Fiscalis 2020 programme, the funding cycle of the  current Fiscalis programme began in 
2021.  However,  as  part  of  the  transition,  unused  resources  from  the  Fiscalis  2020  programme, 
covering both IT projects and collaborative actions, were implemented in 2021 due to delays in the 
adoption of the 2021-2027 MFF and the subsequent late adoption of the Fiscalis Regulation. Training 
activities also continued to be funded through the Fiscalis 2020 budget until December 2021.  

The  budget  allocation  for  the  2021-2024  period  is  distributed  across  several  key  categories,  as 
outlined in the MAWPs and detailed in Table 1 below. As with previous funding periods, most of the 
budget has been committed to the EESs category. For collaboration activities, which include expert 
teams,  EUR  8.5  million  (a  large  sum  due  to  the  fact  that  grants  are  multiannual  as  from  2021 
(covering on average 2-3 years)) was allocated in 2021, with EUR 500 000 allocated in 2022. This 
amount increased again to about EUR 1 million in 2024.  

The ‘other service contracts category’, which covers areas such as training and consultancy, saw an 
allocation of EUR 1.2 million in 2022, which increased to EUR 3.8 million in 2024. This expenditure 
supports the operational activities, and the various external services needed to support the programme. 
In 2021, EUR 70 000 was designated for external experts, but no funds were allocated to this category 
subsequently from 2022 to 2024. 

Overall,  the  total  committed  expenses  for  the  Fiscalis  programme  have  been  relatively  stable, 
increasing  gradually  from  just  under  EUR  34.5  million  in  2021  to  EUR  38.4  million  in  2024. 

10 

 
 
 
Although the total committed expenses exceeded the amount provided for in the MAWP in 2021, 
they have been in line with that amount in subsequent years. 

Table 1. Committed expenses per year and main action categories (in euro) 

Action categories  

2021  

2022  

2023  

2024  

EESs      

22 217 403 

34 654 053 

31 279 783 

33 564 280 

Collaboration 
activities 
expert teams)  

(including 

Other 
contracts  

service 

8 500 000 

500 000 

1 030 000 

1 000 000 

1 
000 
(training) 
2 
701 
(studies) 

000 

701 

1 485 807 

28 63 222 

3 867 952 

External experts  

70 000 

0 

0 

0 

TOTAL  
MAWP 
decision  

financing 

34 489 105 

36 639 861 

35 173 005 

38 432 232 

25 915 550 

36 639 861 

35 678 659 

38 432 232 

Source: Study by Economisti Associati and Fiscalis annual progress reports for 2021-2024 

EESs 

The  Fiscalis  programme  has  devoted  a  growing  budget  to  designing,  developing,  testing  and 
deploying the EESs, which are often mandated by EU law. In fact, these IT systems accounted for 
84% of the programme’s committed expenses for the 2021-2024 period, as depicted in Figure 2.  

Figure 2. EES funding and the Fiscalis budget for the years 2021-2024 

34,5

36,6

34,7

35,2

32,2

38,4

33,6

45
40
35
30
25
20
15
10
5
0

s
n
o
i
l
l
i

M
R
U
E

22,2

2021

2022

2023

2024

European Electronic Systems

Total

Source: Study by Economisti Associati and Fiscalis annual progress reports for 2021-2024 

As  of  2024,  the  programme  is  supporting  30  specific  EESs17,  related  applications  and  their 
maintenance. Table 2 provides an overview of the 17 systems that were undergoing changes in 2022, 
as per MASP-T Rev. 2022 v1.0 (the latest version available online). The table outlines the systems' 

17 Source: 2024 Annual Progress Report. 

11 

 
 
 
 
 
 
architecture,  development  and  operation  models,  and  shows  that  there  is  a  mix  of  centralised, 
distributed and hybrid approaches depending on the system’s scope and implementation.  

In addition to the systems included in the table, Fiscalis supports the maintenance and operations of 
other  systems  developed  under  previous  funding  cycles,  including:  (i)  the  initial  version  of  the 
Common  Communication  Network  /  Common  Systems  Interface  (CCN  /  CSI);  (ii)  the  systems 
supporting  the  previous  DAC  provisions  (DAC1,  DAC2,  DAC3,  DAC4)  and  the  exchange  of 
information under FATCA18; (iii) the systems related to VAT refunds and e-forms recovery; (iv) the 
Taxes in Europe Database (TEDB); (v) the Taxation Statistical System (TSS), etc. 

Table 2. Fiscalis IT systems  

Name 

Acronym 

Description 

Administrative 
Cooperation in Direct 
Taxation 6 (version 4) 

DAC6 

Administrative 
Cooperation in Direct 
Taxation 7 (central 
register) 

DAC7 

Tax Identification 
Number on the Web 

TIN-on-
the-Web 

VAT- eCommerce 
Package 

VIES-on-the-web 

VoW 

Special Scheme for 
SMEs 

Transaction Network 
Analysis 

TNA 

The  purpose  of  DAC6  is  to  provide  Member  States  with  a  central 
directory  for  the  enforcement  of Directive  2011/16/EU on  reporting 
obligations  for  cross-border  tax  arrangements.  The  DAC6  Central 
Directory enables authorities to consult, update and delete records on 
reportable cross-border tax arrangements.  
The  central  register  under  DAC7  will  enable  national  authorities  to 
record 
information  on  platform  businesses  operating  online. 
Specifically,  the  central  application  will  enable  Member  State 
authorities  to  store  and  retrieve  information  about  non-EU  and 
excluded platform operators (independently of the automatic exchange 
of information messages).  
The  TIN-on-the-Web  system  provides  a  web-enabled  interface  that 
enables end users to verify tax identification numbers via a portal. It 
was  launched  in  2012  and  underwent  a  major  update  (v1.12.0)  in 
2020.  
The VAT eCommerce package was adopted in 2017. It extended the 
scope of the MOSS to all types of services and intra-EU sales of goods, 
while  removing  the  threshold  for  VAT  exemption  on  imports.  The 
project  includes  a  number  of  activities,  such  as  customs  projects, 
relevant taxation projects that extend the scope of MOSS (to OSS), a 
database of VAT rates (TEDB) and an update of eForms (EFCA, see 
also dedicated entry below). 
The service enables users to check whether individuals' VAT numbers 
are valid. The system has been operational for several years, but there 
has also been an increase in unauthorised use (i.e. outside the scope of 
Article  31  of  Regulation 
its 
responsiveness needs to be improved.  
The IT system supporting the Special Scheme is not yet operational. It 
should enable authorities to exchange information on companies’ part 
of the scheme to ensure that they continue to meet the scheme criteria.  
TNA is a system that was launched in 2019  to support the Eurofisc 
Network. TNA is used to exchange and jointly process VAT data (and 
detect  suspicious  networks  in  a  more  efficient  way  to  combat  VAT 
fraud). The project seeks to extend the use of TNA to other types of 
fraud  (e.g.  vehicles,  boats,  planes  and  VAT-exempt  imports). 
Additionally,  the  system  is  expected  to  improve  links  with  national 
risk analysis systems.  

(EC)  904/2010).  Furthermore, 

Operation 
method 

Central 

Central 

Central 

OSS: Distributed 
TEDB and 
ECOM-EFCA: 
Central 

Central 

National 

Central 

18 Foreign Account Tax Compliance Act, requiring certain US taxpayers who have financial assets outside the country to 

report those assets. 

12 

 
 
 
 
 
Operation 
method 

Central 

ECMS Core and 
ACO: National 
SEED: Hybrid 

Central 

Central 

Name 

Acronym 

Description 

Central Electronic 
System of Payment 
Information 

CESOP 

Excise Movement and 
Control System 3.4 
Excise Movement and 
Control System 4.0 

EMCS 

EMCS 

Excise Movement and 
Control System 4.1 

EMCS 

Following  the  introduction  of  the  eCommerce  package,  payment 
service providers involved in cross-border payments need to provide 
information  to  Member  States’  authorities  via  CESOP,  a  central 
repository.  
EMCS  is  a  system  for  monitoring  and  controlling  in  real  time  the 
movement of excise goods under suspension. It is based on the register 
of operators in the System for Exchange of Excise Data (SEED). The 
three different phases (3.4, 4.0 and 4.1) modify and expand existing 
features.  Specifically,  phase  3.4 includes  new  messages  for  closure, 
while  phase  4.0  automates  specific  procedures  (for  duty-paid  B2B 
movements35), and phase 4.1 relates to the interface between export 
and excise control systems.  

eForms Central 
Application 

eFCA 
2022 
release 

eFCA is a  web-based central application that aims  to manage the e-
Forms  in  the  context  of  administrative  cooperation in  three taxation 
domains: direct taxation, recovery of claims and VAT. The application 
allows eForms to be managed in a centralised way. The 2022 release 
reflects the changes introduced by the EU27-UK VAT protocol.  

Common 
Communication 
Network 2 

CCN2 

Conformance Testing 
Application 

Conformance Testing 
Applications 

CTA 

CTA 
2022-
2024 
releases 

CCN is a middleware infrastructure that ensures the interoperability of 
distributed  trans-European  systems.  CCN  is  the  infrastructure  
underlying  the  fully  distributed  IT  systems  behind  regimes  such  as 
VAT,  excise  and  customs  processes.  CCN2  represents  the  further 
development  of  the  existing  CCN  architecture  and  it  uses  an  SOA. 
Currently,  CCN2  is  being  delivered  in  several  releases  in  order  to 
control risks.  

CTA is a service that helps Member States check the 
conformance  of  nationally  developed  applications  embedded  in  the 
EESs.  

Central 

Source: Study by Economisti Associati and MASP-T 

Collaborative actions, including expert teams 

The  Fiscalis  programme  provides  a  framework  for  tax  authorities  to  work  together.  It  enables 
cooperation through a variety of operational actions during which knowledge, experience and good 
practices are exchanged, and practical outputs such as guidelines and recommendations are produced. 
These  activities  all  involve  bringing  together  national  tax  officials,  Commission  officials  and,  in 
specific cases, other stakeholders. Programme funding is mainly used to cover participants' travel, 
subsistence and  accommodation unit costs,  although  salary costs  are  also covered  for one type of 
action (expert teams, described below). 

The  programme  has  devoted  7.6%  of  its  committed  expenses  for  2021-2024  to  supporting 
collaborative actions, as shown in Figure 3. 

13 

 
 
 
Figure 3. Funding for collaborative actions and the Fiscalis budget 

45

40

35

30

25

20

15

10

5

0

s
n
o
i
l
l
i

M
R
U
E

34,5

36,6

35,2

38,4

8,5

2021

0,5

2022

1,0

2023

1,0

2024

Collaboration activities/expert teams

Total

Source: Study of Economisti Associati and Annual Progress Reports 2021-2024 

Collaborative actions include a wide variety of activities that fall in the following main categories: 

•  project-based structured collaboration, which includes: 

-  project groups, typically consisting of representatives from a limited number of countries, 
working  together  for  a  specified  period  to  achieve  a  defined  objective  with  clear 
outputs/results (such as coordination or benchmarking); 

- 

expert teams, which are (either temporary or permanent) structured forms of cooperation that 
pool expertise from national tax authorities to carry out tasks in specific domains or perform 
operational activities, with the main difference between expert teams and project groups being 
that the Fiscalis programme not only covers expenses (e.g. travel and allowances) related to 
meetings but also compensates the working time of the experts involved, in recognition of the 
more intense effort required of expert teams; 

•  meetings and other ad hoc events, such as seminars, workshops and working visits; 

•  reinforced cooperation tools, including in particular: 

-  multilateral  or  simultaneous  controls  and  joint  audits  involving  the  coordinated 
examination of the tax situation of one or more taxable persons, conducted by two or more 
countries, including at least two Member States with shared or complementary interests; 

-  presence  in  administrative  offices  and  participation  in  administrative  enquiries 
(PAOEs),  in  which  tax  officers  from  one  Member  State  visit  another  country  to  examine 
documentation or participate in enquiries. 

All collaborative actions, except for expert teams, are managed jointly under the general collaborative 
action grants, while each expert team is managed as an individual grant. Between 2021 and 202419, 
225  collaborative  actions20  took  place,  involving  a  total  of  2 222  participants  (excluding  expert 

19 This analysis uses ART data from 2021 to mid-2024, when it was extracted. 
20 The total number of actions includes only those specified above and does not account for other actions such as selection 

meetings (FAC codes), and CLEP (FTR codes). 

14 

 
 
 
 
 
 
teams). According to Figure 4, which breaks down the collaborative action types by the number of 
actions, multilateral controls (MLCs) and project groups are predominant, followed by workshops, 
PAOEs and seminars.  

Figure 4. Collaborative actions between 2021 and 2024 (excluding expert teams) 

Seminars
1%

IT training
2%
Working visits
10%

Multilateral 
controls
34%

PAOE
16%

Workshops
16%

Project groups
21%

Source: Economisti Associati study using ART data from 2021 to mid-2024 

Just over EUR 11 million was  committed across the various categories of collaborative activities 
(including  expert  teams)  from  2021  to  2024.  Project  groups  received  the  largest  portion  of  this 
spending  (EUR 2.37  million)  .  The  next  highest  expenditure  was  on  workshops  (EUR 595 000), 
followed by  training (EUR 538 000) and MLCs (EUR 382 000). Smaller amounts were allocated to 
PAOEs, working visits, seminars and host-initiated working visits. 

Figure 5. Share of expenses by categories of collaborative actions under Fiscalis 2021- 2024  

Working visits
1%

Seminars
0,4%

PAOE
2%

Multilateral 
controls
10%

Training
13%

Workshops
15%

Project groups
59%

Source: Economisti Associati study using ART data from 2021 to mid-2024 

➢  Project groups 

By mid-2024, 44 project groups had been initiated since the start of the programme, providing an 
umbrella for different activities. Many of these groups focus on thematic aspects of tax policy, while 
others  are  dedicated  to  the  development  and  use  of  IT  systems.  In  addition  to  these  two  broad 

15 

 
 
 
 
 
 
categories,  there  are  also  cross-cutting  group  activities  on  managing  and  implementing  the 
programme itself. Each project group involves participants from 18 countries on average. 

Most of the meetings for these groups were conducted online (53.1% of all meetings), while 39% of 
the meetings were held in person and 7.9% were organised as hybrid events. It is important to note 
that the percentage distribution might not be fully representative due to the impact of post-COVID 
conditions in 2021/2022, which influenced the mode of meetings during this period. 

➢  Workshops, seminars and working visits 

A total of 33 workshops were held from 2021 to mid-2024, with 769 participants. There were also 
2 seminars, which involved 49 participants, and 23 working visits, including both working visits 
and host-initiated working visits, attended by 68 participants. These collaborative actions cover a 
wide range of topics, primarily focusing on areas such as transfer pricing and the pre-filling of tax 
returns.  These  actions  also  address  administrative  capacity  building,  promoting  cooperation 
between tax authorities, and improving the overall efficiency of tax systems. 

➢  MLCs and PAOEs 

The Fiscalis programme has supported the implementation of 71 MLCs and 33 PAOEs, focusing 
primarily  on  improving  tax  systems,  particularly  in  specialised  fields  such  as  e-commerce  and 
administrative capacity building. These actions were carried out across 14 countries. 

➢  Expert teams 

Expert  teams  involve  national  tax  specialists  working  on  targeted  policy  areas.  These  teams 
require  a  greater  time  commitment,  a  higher  level  of  expert  involvement,  and  a  broader  scope  of 
budget coverage, which includes both travel and salary expenses for national tax authorities. Expert 
teams  must  bring  together  at  least  five  participating  countries  and  typically  operate  for  18  to  36 
months, with the possibility of renewal. Their activities may blend virtual interactions with in-person 
meetings.  Although  they  lack  legal  personality,  expert  teams  require  a  well-defined  structure, 
including roles for the project manager and grant agreement coordinator. DG TAXUD policy units 
monitor the progress of deliverables, timelines and overall adherence to the expert team’s objectives. 
According  to  the  available  APRs,  seven  expert  teams  were  proposed  under  the  current  Fiscalis 
programme, with the following five expert teams having either been launched or concluded by 2024. 

•  TNA:  the  TNA  expert  team,  which  was  initially  launched  in  2020,  has  undergone  several 
iterations, of which only TNA III (2024-2027) is funded under the current Fiscalis funding 
cycle. It aims to increase Eurofisc’s operational efficiency by: (i) improving fraud detection 
tools; (ii) promoting inter-agency cooperation; and (iii) strengthening responses to complex 
VAT  fraud  schemes,  including  VAT  exemptions  on  imports  and  fraudulent  vehicle 
transactions. 

•  Managed IT Collaboration (MANITC V): launched in late 2021, the MANITC V expert 
team continued its operations throughout 2023, providing support for IT collaboration in the 
taxation domain, which included helping to integrate AI into tax operations. 

16 

 
 
•  Development  of  data  analysis  tool  (DATANA):  launched  in  early  2022,  the  DATANA 
expert team aimed to improve the handling of data exchanged under the DAC provisions on 
automatic exchange of information (AEOI) that remained unmatched (i.e. that could not be 
linked to taxpayers in national datasets). The expert team completed its work in January 2024, 
delivering a prototype tool for the analysis of unmatched DAC data. 

•  Central  Electronic  System  of  Payment  Information  (CESOP):  the  CESOP  expert  team 
helped the Commission to create a central system for processing payment data related to cross-
border e-commerce transactions. The first version of CESOP ran from February 2021 to May 
2023, and the second version was launched in January 2024. 

•  Visits to Member States Directive on Administrative Cooperation (VISDAC): launched 
in February 2023, the VISDAC expert team has helped Member States to implement the DAC 
effectively. By the end of 2024, all planned visits had been completed. 

Two expert teams (the expert team for the EU cooperative compliance pilot project for larger 
companies  and  the  expert  team  on  excise  distance  selling)  that  had  initially  been  planned  were 
cancelled due to a change in circumstances and replaced with project groups. 

Capacity building  

A  range  of  training  initiatives,  such  as  CLEP  events,  e-learning  courses,  IT  training  sessions  and 
webinars, have been carried out since 2021. A key new feature introduced by the current programme 
was the launch of the LMS in May 2021, along with its public interface, the  Customs & Tax EU 
Learning  Portal.  This  platform  serves  as  a  centralised  access  point  for  all  training  materials  and 
capacity-building opportunities, offering e-learning courses, webinars, nano-learning modules and e-
books. It also acts as the place to register for CLEP training sessions, which include both in-person 
and online learning events. While the total budget for all capacity-building activities combined was 
unavailable (and indeed some actions are captured under the budget lines covered above), it is worth 
noting that the LMS platform had received about EUR 1.5 million by the end of 2024, which is shared 
between the Customs and Fiscalis programmes. About EUR 1 million of the cost was incurred during 
the current funding cycle, while the rest came from the Customs 2020 and Fiscalis 2020 budgets. In 
addition, EUR 540 000 were spent to fund tax officers' participation in IT training sessions and CLEP 
events21. 

The Customs & Tax EU Learning Portal is the primary training platform in the fields of customs 
and  taxation.  It  is  specifically  designed  for  tax  and  customs  officials,  but  it  also  serves  a  broader 
audience, including economic operators and academics. Many resources are accessible through an 
EU login, while some specialised or technical courses are restricted to specific groups, such as tax 
and customs officials. 

Users can take the courses directly on the platform or download them for use via national systems. A 
specific  functionality,  Learning  Tools  Interoperability  (LTI),  allows  users  to  access  courses 
through their national LMS while still ensuring that data on engagement and completion is tracked 

21 Based on ART data on expenditures. 

17 

 
 
 
 
by the EU LMS. This  provides flexibility  for national authorities and participants, while enabling 
centralised monitoring and assessment. 

Finally, the portal also serves as a repository where different Member State tax and custom authorities 
can upload and share learning materials as contributors, and access direct interaction between users 
in the forum section.  

Over 160 resources (1 e-book, 111 e-learning courses 29 nano-learning courses 3 LTIs, 18 webinars) 
are available on the portal and approximately 30 CLEP events are organised per year. 

Figure 6. LMS resources between 2021 and 2024 

111

120

100

80

60

40

20

0

29

18

3

1

E-learnings Nano-learnings Webinars

LTIs

E-books

Source: DG TAXUD course catalogue 

4.  EVALUATION FINDINGS (ANALYTICAL PART) 

This chapter presents the main findings of the evaluation under three broad questions that cover the 
five evaluation criteria. The first question (covering the evaluation criteria of effectiveness, efficiency 

18 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
and coherence) investigates the extent to which the Fiscalis programme has been successful and why. 
The  second  question  (covering  the  evaluation  criterion  of  the  EU  added  value)  assesses  how  the 
Fiscalis programme has made a difference, and to whom. Finally, the third question (covering the 
evaluation criterion of relevance) examines whether the Fiscalis programme is still relevant.  

The evaluation draws on a variety of fact-finding activities as carried out in the supporting external 
study  conducted  between  2024  and  2025.  These  activities  include,  among  other  things,  five  case 
studies, four of which cover some of the EESs funded by Fiscalis, while the fifth focuses on the LMS. 
The box below presents an overview of the case studies' most important features. Annexes II and III 
of this document contain a more detailed analysis of the case studies. 

Box 1. Overview of the case studies 

TNA 

•  TNA is a centralised, automated risk analysis platform supporting Eurofisc’s fight against cross-border VAT 
fraud,  especially  missing  trader  intra-community  (MTIC)  and  carousel  fraud  (whereby  illicit  traders  claim 
repayments for input VAT that was never incurred).  The system enables real-time data exchange and network 
analysis among national tax authorities for the early detection of fraudsters and fraud facilitators. Operational since 
2020, TNA replaced manual Excel-based data exchanges of information, which were time-consuming and affected 
by  quality  issues  (e.g.  clerical  errors  in  compilations,  missing  information,  different  formats).  When  it  was 
introduced, TNA covered only MTIC fraud, but its scope was subsequently expanded to include VAT fraud that 
involves the violation of customs procedures (2021) and fraud related to means of transportation (2023).  

•  Key findings: TNA was found to be highly effective in: (i) detecting VAT fraud; (ii) enabling early warnings; 
(iii) improving the targeting of tax controls; and (iv) supporting real-time collaboration between Member States. 
Between its introduction in 2020 and 2023, some EUR 37 billion in suspicious transactions were uncovered22, 
with  over  12 000  fraudsters  being  identified  and  6 000  deregistered  for  VAT.  TNA  also  achieved  significant 
success in preventing fraud by identifying fraudsters early and thus reducing their lifespan and, consequently, the 
volume of their fraudulent activities. The system also led to significant cost savings for tax authorities (in the 
order  of  EUR  1.7  million  by  2024)  by  automating  data  collection  and  processing.  Further  (likely  significant) 
savings are generated by streamlining bilateral interactions, which can now be carried out on the system instead 
of through lengthy administrative procedures. 

DAC 6 Central Directory (CD) 

•  The DAC6 CD is a central repository for exchanging information on reportable cross-border arrangements 
that  might have some tax avoidance consequences, in compliance with the obligation stemming from the fifth 
amendment to the Directive on Administrative Cooperation23 (or DAC6). Under DAC6, information is collected 
from reporting entities (tax advisers and other intermediaries or, as  a last resort,  taxpayers) through nationally 
developed systems, and then transmitted machine-to-machine  to the CD. The process is highly automated and 
requires  little  or  no human  intervention.  Similar  processes  are  used  to bulk  download  information  on  national 
repositories to be used for tax controls and risk assessment by national tax officials.  

•  Key findings: the case study suggests that DAC6 CD works well, and stakeholders only pointed out minor issues 
or  possible  improvements.  Most  tax  authorities  believe  that  a  centralised  system  (as  opposed  to  bilateral 
exchanges) is the right choice for these types of exchanges, although implementing a centralised system  is not 
necessarily  less  costly  than  bilateral  exchanges.  Tax  authorities  largely  agree  that  DAC6  CD  has  three  main 
advantages.  Firstly,  it  reduces  the  costs  of  follow-ups  compared  with  bilateral  interactions.  Secondly,  it 

22 The suspicious transactions uncovered between 2021 and 2023 amounted to nearly 34 million. 
23 Council Directive 2011/16/EU of 15 February 2011 on administrative cooperation in the field of taxation and repealing 

Directive 77/799/EEC. 

19 

 
 
 
 
 
automatically generates statistics and monitoring data, which would otherwise need to be produced by national 
tax authorities, with the consequent savings in terms of effort. Notably, these two categories of cost savings, while 
not quantifiable, appear clearer for smaller or less automated administrations. Thirdly, the CD has advantages in 
terms  of  transparency  compared  with  bilateral  exchanges.  Overall,  the  DAC6  legislation  has  yet  to  yield 
tangible benefits, which means that it is also too early to see the CD's quantitative benefits.  

Vies on-the-web (VoW) 

•  VoW is a web interface that is integrated with the VAT information Exchange System (VIES). Launched in 
2001, VoW allows economic operators to verify business partners’ VAT numbers. Operating on a real-time 
basis, each validation request made through VoW is instantly forwarded to the relevant administration's national 
VIES system. If the entered VAT number is valid, the  platform confirms its validity. If that is not the case, the 
platform notifies users that the VAT number is invalid for cross-border transactions within the EU. Additionally, 
it advises economic operators to reach out to the appropriate authorities for corrections or clarifications, providing 
a useful link to the national tax authorities for further assistance. Before VoW became operational, the verification 
of VAT numbers was cumbersome and varied significantly in different country-specific contexts. The process for 
providing VAT details (including the VAT identification number of the  buyer and the VAT amount due) was 
manual and fragmented, often requiring the consultation of national VAT databases, direct communication with 
tax authorities, or contact with trading partners. The launch of VoW marked a significant step towards centralising 
and digitising the VAT number verification process, streamlining it for traders. 

▪  Key findings: the case study found evidence that VoW has provided economic operators with a rapid, reliable and 
centralised  system  for  VAT  number  verification,  dramatically  changing  the  processes  and  tools  available  for 
business and tax officials to verify VAT numbers. By standardising verification practices, VoW reduces national 
disparities  in  data  access  and  improves  operational  efficiency  for  businesses.  Its  main  benefits  include  a 
reduced administrative burden, and better VAT compliance and VAT enforcement. The centralisation of VAT 
number verification delivers substantial cost savings, as tax authorities and economic operators would incur 
higher costs in the counterfactual scenario. VoW allowed both tax authorities and economic operators to achieve 
average cost savings in the order of EUR 62 million between 2021 and 2023, with a cost/benefit ratio of 7.524. 
VoW  also  demonstrates  significant  EU  added  value  by  providing  an  EU  platform  for  rapid,  reliable  and 
centralised  VAT  number  verification,  which  ensures  interoperability  with  national  VIES  systems,  brings 
consistency and uniformity and lowers costs for tax administrations and businesses. Finally, the VAT in the Digital 
Age initiative and the growing adoption of e-invoicing are expected to increase VoW’s capabilities and usage in 
the future. The case study also identified significant areas for improvement, including improvements to the user 
interface and platform accessibility, adjusting the daily limit on requests and modernising the API interface.  

Excise Movement Control System (EMCS)  

•  The purpose of the EMCS is to track the movement of excisable goods (alcohol, tobacco and energy products) 
throughout  the  EU.  It  aims  to  improve  the  efficiency,  safety,  security  and  environmental  footprint  of  the 
monitoring  of  such  goods.  The  system  monitors  several  key  types  of  information  including:  (i)  the  economic 
operators; (ii)  the consignors (the sender of the excisable good) and consignees (the recipient of the excisable 
good), who have to be registered; (iii) the type of excisable good (listed in the EMCS code sheet); (iv) the details 
of the provider of the mandatory movement guarantee; and (v) even the details of the transporter. Structurally, 
EMCS is a complex,  distributed system with both central and Member State components. The Commission is 
responsible  for  developing  and  maintaining  several  components,  including:  (i)  the  SEED  database,  a  central 
registry which is used to automatically verify the validity of every movement against the trader records before the 
goods  are  approved  and  moved;  (ii)  the  SEED-on-Europa  application,  a  data-searching  tool,  which  allows 
economic  operators  to  check  the  validity  of  a  SEED  number  in  any  Member  State;  and  (iii)  several  other 

24 For a detailed breakdown of these cost savings, please refer to Table 14 (‘Overview of costs and benefits’) and the 

accompanying explanatory paragraph, which can be found in Annex IV of the SWD. 

20 

 
 
 
components,  such  as  the  EMCS  Core,  EMCS  ACO,  ARC  follow-up  and  the  CCN/CSI.  Since  2020,  the 
Commission has also developed key updates to the system that have added to its scope and functionality.  

•  Key findings: EMCS is effective and fit for the purpose of helping Member State competent authorities and 
economic operators to improve excise trade procedures and traceability/monitoring, and fight fraud. Despite being 
difficult to quantify, the benefits of most of the components outweigh the costs (compared with the counterfactual). 
The central SEED database (which, arguably, delivers the most significant added value) underpins much of the 
automation (and benefits) of EMCS. Evidence shows that without the central SEED, both national authorities and 
economic operators would have to redeploy resources for highly repetitive and manual tasks, such as verifying 
electronic administrative documents (eADs). In contrast, although the SEED-on-Europa tool is widely used by 
national authorities and economic operators, its usefulness is limited. This is because economic operators must 
still carry out due diligence by other means, given that the tool only verifies SEED numbers, rather than providing 
key information such as a company name or address. The case study found evidence that  each of the updates 
have  been  valuable  to  national  authorities  and  certain  economic  operators,  yielding  tangible  benefits  (e.g. 
reduced waiting times, business planning, possibility to redeploy resources) but that adjusting to the updates and 
related  process  changes  has  also  entailed  significant  costs  for  these  stakeholders.  Multinational  operators 
expressed some dissatisfaction due to inconsistent approaches to national implementation, which meant that they 
had to operate different systems in which they were active (with significant cost implications), prompting calls for 
more coherent implementation by the national administration.  

LMS 

•  The LMS, officially known as the Customs & Tax EU Learning Portal was launched in 2021 as a central location 
for  the  e-learning  courses  developed  as  part  of  the  Customs  and  Fiscalis  programmes,  as  well  as  for  the 
organisation of events for the CLEP. The portal can be used for the e-learning courses in three different ways, 
namely by: (i) taking a course directly on the platform; (ii) downloading and posting a course on a national LMS; 
and/or (iii) using the LTI functionality, which allows courses to be embedded in a national LMS while still being 
run  from  the  EU  LMS  at  the  back  end.  This  is  important because  LTI  allows  both  DG  TAXUD  and  national 
administrations to collect detailed data on usage. The platform was developed and is managed by DG TAXUD 
with the support of an external contractor, and the Member States have provided input throughout the process via 
the TSG, a project group bringing together national training coordinators from tax and customs authorities. While 
the main audience is customs and tax officials, economic operators and other stakeholders may use the LMS to 
access certain publicly available material. 

•  Key findings: regarding the rationale behind the LMS and how the LMS satisfies needs, the case study found 
that it satisfies a strong need to collect and organise the e-learning catalogue in a single, easily searchable place. 
It also aims to provide a platform for stakeholders to take the courses directly, although this need is peripheral for 
most Member States due to the widespread existence of national LMSs. The design of the LMS was also assessed 
positively, with stakeholders praising its user-friendliness, navigation, layout and organisation, and visual design, 
as well as the quality and  usefulness of its core functionalities. On  usage and impact, the available metrics 
suggest that the LMS is becoming increasingly established and serving its business function, with user numbers 
continuing to grow. Overall, the LMS adds significant value at reasonable cost, fulfilling its role as the single 
repository  for  e-learning  courses  and  CLEP  event  registration.  With  a  view  to  the  future,  several  potential 
incremental improvements have been identified, ranging from improvements to the search function, to efforts 
to increase the uptake of LTI. 

Source: study by Economisti Associati. 

4.1  To what extent was the intervention successful and why?  

The answer to this question is based primarily on the assessment of the effectiveness of the Fiscalis 
programme, i.e. how successful it has been in achieving or progressing towards its objectives, and 
why. To assess this criterion, the evaluation  looks at the implementation and achievements  of the 

21 

 
 
 
different types of activities and their contribution to the programme’s objectives. The response also 
considers: 

•  efficiency,  in  terms  of  the  costs  and  benefits  experienced,  and  administrative  burdens  for 

stakeholders; and  

•  coherence, with regard to the programme's alignment with other relevant EU initiatives and 

internal organisation. 

Effectiveness 

The assessment of effectiveness explores the extent to which the programme produced the expected 
specific deliverables (outputs) and achieved the targeted results (outcomes – or specific objectives; 
and – or general objectives).  

Figure 7. Fiscalis programme results chain 

Source: Economisti Associati study elaboration form MEF SWD 

➢  Over the time covered by the evaluation, the Fiscalis programme has helped to improve tax 

authorities' administrative and operational capacity 

Fiscalis support for developing EESs  

Since the start of the funding cycle in 2021, the programme has helped to develop, roll out, maintain 
and update the central components of 30 EESs25. The systems supported cover different tax areas, 
including the area of direct taxation and indirect taxation (e.g. the IT systems, such as VIES or the 
TNA, which support the automatic exchange of information under the Directive on Administrative 
Cooperation) and the area of excise (including all the systems that make up the EMCS), as well as 
horizontal infrastructure and information systems, such as CCN & CCN2 (which are also used 
by  IT  systems  in  the  area  of  customs).  The  EESs,  which  include  both  centralised  systems  and 

25 See Annual progress report – 2024. For more details, see Section 3.1. 

22 

 
 
 
 
 
 
distributed  (i.e.  decentralised)  models,  are  also  very  diverse  in  terms  of  operational  methods  and 
architecture.  

Every year since 2021, the number of IT projects in the ‘executing phase’26 has reached or surpassed 
the targets established. The projects entered into production as expected, including EMCS 4 in 2023, 
and CESOP and EMCS 4.1 in 2024. Additionally, the central components of the EESs supported by 
Fiscalis are highly reliable, with rates of availability close to 100%27, and the support services are 
generally effective and considered satisfactory by users28. 

The environment composed of the EESs allows tax authorities to interact securely, reliably and 
effectively with economic operators. This was confirmed further across the four systems assessed 
through dedicated case studies.  

•  The  TNA  provides  a  platform  for  tax  authorities  to  interact  and  cooperate,  improving  the 
security and the quality of the information exchanged among Eurofisc officials. The system is 
also appreciated as it allows swift and easy interactions among tax authorities, which would 
previously have required lengthy administrative procedures.  

•  Since its launch in mid-2020, nearly 70 000 disclosures of cross-border arrangements have 
been exchanged on the DAC6 CD. The system is considered to be secure and to function well, 
with the information exchanged improving risk assessment and risk management at national 
level. 

•  The EMCS has over 223 500 individual users and, since 2019, over seven million messages 
have  been  exchanged  on  the  system.  The  system  helps  to  streamline  otherwise  complex 
processes related to the movement of excise goods, allowing real-time monitoring and swift 
interactions between economic operators and tax authorities. 

•  The number of messages exchanged on VIES-on-the-web has increased fivefold since 2014, 
from 1 billion to 4.8 billion. Users praise the system's speed, which allows VAT numbers to 
be checked in less than one minute in a credible and reliable manner. This, in turn, enables 
economic operators to comply with the regulatory obligation of using just one EU platform 
instead  of  27  different  national  ones  to  check  the  validity  of  the  VAT  number  of 
clients/suppliers.  

Implementation of collaborative actions 

Since 2021, the Fiscalis programme has funded many collaborative actions, which have grown 
over the years both in terms of the number of actions and the number of outputs that they produce 
(including working practices, guidelines and recommendations). Between 2021 and mid-2024, 225 
collaborative actions took place, with a total of 2 222 participants. 

The collaborative actions are also widely appreciated by participants, who praise the quality of 
the events and the extent to which they are relevant for their work. In line with the findings of the 

26 MEF indicator OP 1.1 sub-indicator 2 (MEF SWD, APR 2021, 2022, 2023, 2024). 
27 Source: MEF, Annual progress reports. 
28 MEF indicators OP 1.3 (Proportion of ‘incident’ tickets resolved on time) is between 96% and 99%. 

23 

 
 
 
 
previous evaluation, the consultations carried out for this exercise suggest that according to officials 
from participating administrations, almost all the tax administrations consider the actions funded 
by the programme to be useful29. The feedback is positive for expert teams in particular, and for 
other types of actions. 

Figure 8. Usefulness of collaborative actions 

How useful are collaborative actions to the work of your 
administration?

25

20

15

10

5

0

Very useful

Useful

Not very useful

Don’t know

Expert teams

Other collaborative actions

Source: Economisti Associati supporting study (number of respondents: 22) 

While the content and effectiveness of training actions, such as e-learning, CLEP sessions and IT 
capacity-building activities were not assessed in detail, no evidence has emerged to cast doubt on the 
validity  of  the  previous  evaluation's  conclusions.  These  were  very  positive  and  emphasised 
participants’ high degree of satisfaction with the activities. The e-learning catalogue has expanded 
over time and now encompasses 165 courses in English and 1 100 ‘localised’ versions relevant either 
only to taxation or to both customs and taxation. Moreover, the LMS, which was introduced for 
the current funding period, has improved the dissemination of the training material compared 
with  the  previous  arrangements,  allowing  the  training  material  to  reach  a  larger  audience  and 
providing a better user experience.  

Overall,  the  support  for  both  IT  capacity  building  and  the  collaborative  actions  has  contributed 
significantly to strengthening the tools and skills at the disposal of Member State tax authorities, 
thus reinforcing their capabilities and enhancing their operational performance. 

This  also  emerged  in  the  case  studies  concerning  EES  systems  that  were  examined  during  the 
evaluation. 

•  The performance of national tax officers involved in the fight against VAT fraud, which is an 
intrinsically intra-EU cross-border problem, has been substantially improved – both directly 
and indirectly – by the introduction of the TNA. The direct improvements concern the quality 
of the information and, most of all, of the analysis provided by the system, which equips case 
workers  with  improved  and  better-targeted  information  on  which  to  base  their  checks  and 
investigations.  The  indirect  improvements  concern  the  simplification  and  speeding  up  of 

29 Programme survey of national fiscal coordinators within national tax authorities, conducted in the context of the study 

supporting the evaluation. See also Annex V for a more in-depth overview of the consultation activities. 

24 

 
 
 
 
 
 
cooperation and the exchange of information, thereby freeing up officers’ time and allowing 
it to be reallocated to actively tackling VAT fraud. 

•  Similar observations could be made regarding the DAC6 CD, for instance, which allows the 
exchange of information on potentially aggressive cross-border agreements. In this way, the 
system  provides  tax  authorities  with  a  wealth  of  relevant  data  that  can  be  used  to  close 
legislative loopholes and perform more targeted risk-based assessments. 

Likewise,  the  outputs  of  the  collaborative  actions  (such  as  working  practices,  guidelines,  etc.) 
contributed to improving tax authorities' operational performance, as confirmed in a 2023 survey of 
national administrations30. In particular, the outputs produced by the activities are generally used by 
tax  officers31,  for  example,  to  share  the  knowledge  acquired  with  other  colleagues  within  their 
administrations and to improve working practices, and operational and administrative procedures32.  

➢  Fiscalis has helped to improve cooperation among tax authorities in the area of taxation  

The  Fiscalis  programme  supported  cooperation  among  tax  authorities  both  by  introducing  and 
improving  IT  systems,  and  by  creating  cooperation  and  networking  forums  through  collaborative 
actions. 

In particular, the IT systems offer new and improved  platforms that make interactions easier 
and  faster,  and  encourage  direct  collaboration  and  the  identification  of  common  solutions.  For 
instance, one of the aspects of TNA that was praised the most – and is probably responsible for much 
of  the  cost  savings  generated  –  is  the  possibility  for  tax  authorities  to  interact  swiftly  by  sending 
messages  and/or  sharing  documents  on  the  system,  instead  of  having  to  rely  on  slower  and  more 
burdensome formal bilateral cooperation procedures.  

Likewise, 80% or more of the tax officers of participating countries33 recognise that the creation of 
networking opportunities for tax officials is one of the key aims of collaborative actions. The 
collaborative actions funded by Fiscalis featured a number of ‘reinforced’ cooperation instruments, 
including working visits, multilateral controls and PAOEs. These actions, allowing direct bilateral 
or multilateral interactions among tax officers of different administrations, are regarded as flagship 
examples of fruitful cooperation supported by the programme.  

Several group activities have aimed to offer national tax administrations opportunities to collaborate 
more  closely.  In  particular,  the  national  tax  authorities  consulted  highlighted  two  project  groups 
funded by the Fiscalis programme as important examples in this respect. This concerns the TADEUS, 
and the Eurofisc networks, as well as project groups that aim to share best practices on specific issues 
(e.g. in dealing with data issues, or taxes on non-alcoholic beverages)34. The VISDAC expert team 

30  In  the  2023  survey,  25  out  of  27  administrations  noted  that  collaborative  actions  contributed  to  some  extent,  or 

significantly, to their operational performance. 

31 MEF RES 1, sub-indicator 1: the percentage of national officials reporting that their authorities made use of a working 
practice, guideline or recommendation developed with the support of the programme: 79% in 2022; 70% in 2023; 
80% in 2024. 

32 2023 Fiscalis programme national survey. 
33 Indicator set out in Annex II to Regulation (EU) 2021/847. 
34 Programme survey to National Fiscal Coordinators within national tax authorities conducted in the context of the study 

supporting the evaluation. See also Annex V for a more in-depth overview of the consultation activities. 

25 

 
 
 
 
was also highlighted as having a positive impact on networking and the exchange of best practices. 
While participants in the team were already familiar with the issues at stake, tax officers had a chance 
to share experiences and increase their knowledge of the approaches used in other Member States 
when dealing with certain DAC provisions.  

Importantly, the creation of a strong network among NPCs is both a result and an important input 
of  the  programme,  particularly  regarding  collaborative  actions.  The  meetings  of  the  national 
coordinators network  –  and, in  particular, the chance to  meet  in  person  periodically  – are seen as 
invaluable to fostering seamless interaction and sound management of the collaborative actions. This 
seems  to  be  even  more  relevant  under  the  current  funding  cycle,  as  the  new  grant  management 
arrangement, which relies on a consortium of tax authorities for implementation and administration, 
requires a deep level of trust and mutual confidence among Member States, especially between the 
grant coordinator and the other consortium members.  

➢  The programme's actions helped to implement EU tax law uniformly and, thus, to improve 

the functioning of the EU single market 

Fiscalis support for the common components of the EESs represents an essential element of EU tax 
policy  and  its  implementation.  Since  most  of  the  recent  EU  tax  policies  and  legislation  require  a 
digital solution, IT capacity building is indispensable for the operationalisation of new initiatives 
and  actions.  This  is  the  case,  for  instance,  for  all  DAC  AEOI  provisions.  The  Directive,  in  fact, 
obliges the Commission to: (i) develop and maintain the central components of the infrastructure and 
software necessary for the exchanges, which typically also provide access to horizontal infrastructures 
(e.g.  CCN/CCN2  and  CSI);  and/or  (ii)  develop  central  systems  (e.g.  DAC6).  As  discussed  in  the 
dedicated case study, the IT solution conceived influenced the design of the policy, with the two being 
completely intertwined.  

In other cases, IT systems have improved and strengthened the implementation of existing or 
evolving  provisions.  For  instance,  the  introduction  of  the  EMCS  streamlined  and  improved  the 
processes  related  to  the  movement  of  excise  goods,  allowing  the  transition  from  paper-based  to 
electronic  processes  to  be  made.  This  helped  not  only  to  simplify  and  reduce  the  administrative 
burden  on  economic  operators,  but  also  to  strengthen  tax  authorities’  ability  to  monitor  the 
movements, thereby helping to implement the related policy fully.  

The role of collaborative actions in implementing EU tax law uniformly is recognised across the 
board by the stakeholders consulted, both in individual case studies and in the overall programme 
assessment35.  Those  actions  provide  forums  for  national  tax  officials  to  exchange  best  practices, 
develop common standards for the implementation of rules or the uptake of IT systems, and share 
views and experiences  across different  legal,  institutional  and cultural  backgrounds, in  a way that 
would not be possible without the programme.  

35 See Annex V for a more in-depth overview of the consultation activities. 

26 

 
 
 
 
From an operational viewpoint, collaborative actions contribute to the implementation of EU law in 
several different ways, some of which are set out below.  

•  There are structured activities, such as those carried out by project groups and expert teams 
(including  the  TNA  and  the  CESOP  expert  teams)  that  have  engaged  in  the  design, 
development,  roll-out  and  training  of  the  IT  systems  funded  by  the  programme.  Those 
structured  activities  are  complemented  by  numerous  events,  such  as  IT  training  sessions, 
CLEP events, workshops and seminars that aim to build the skills of tax authorities in using 
the new or improved systems. 

•  There are also actions that aim to support uniform implementation through long-lasting 
or  permanent  activities  with  operational  functions.  Such  actions  are  carried  out  by 
dedicated project groups, such as the EU Advanced International Administrative Cooperation 
(AIAC)  community,  the  standing  committee  for  the  implementation  of  Article 10  of  the 
Directive on tax dispute resolution mechanisms in the EU, or by the project groups supporting 
the implementation of the GloBE minimum tax directive, the VAT OSS and the VAT scheme 
for SMEs, as well as numerous workshops and seminars. Within these forums, tax authorities 
can exchange best practices to strive for the harmonised implementation of EU tax law and to 
ensure the adoption and uptake of the related IT systems. 

•  Other  activities,  such  as  MLCs  and  PAOEs,  focus  on  compliance  and  correct 
implementation. These activities allow Member States to concentrate on compliance with 
the conditions  of EU legislation,  but  they do not necessarily focus on differences between 
countries. In a similar vein, most of the training actions, particularly the e-learning modules, 
are  focused  on  helping  stakeholders  to  correctly  implement  or  (in  the  case  of  economic 
operators) comply with EU tax legislation. 

Interaction between programme support for EESs and collaborative actions 

While both IT systems and collaborative actions contribute to the implementation of EU tax law, and 
thus to the functioning of the single market, they do so through different channels. IT systems are 
an increasingly integral part of EU tax policies and law (often stemming from a requirement in 
EU law) and thus contribute directly to the creation of a level playing field. In this respect, the role 
of  collaborative  actions  and  learning  activities  is  inextricably  connected  to  the  uniform 
implementation of tax policies and laws, and to their uptake. This second aspect is essential for the 
policies to produce the desired results. 

➢  The programme supported the fight against tax fraud, tax evasion and aggressive tax planning, 

helping to protect the financial interests of the EU and its Member States 

This evaluation confirmed the key conclusions of the final evaluation of the Fiscalis 2020 programme, 
which  found  that  the  programme  had  supported  the  fight  again  tax  fraud,  tax  evasion  and 
aggressive  tax  planning.  This  emerged  also  from  the  feedback  collected  from  national  Fiscalis 

27 

 
 
 
coordinators, who highlighted that all three types of activities, i.e. EESs, collaborative actions and 
capacity-building activities, have continued to generate positive effects in this respect (see Figure 9)36. 

Figure 9. NFCs feedback on activities’ contribution to the fight against tax fraud 

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

The IT systems funded by the Fiscalis programme
contribute to the fight against tax fraud, tax evasion and
aggressive tax planning

3

3

16

The collaborative actions funded by the Fiscalis
programme contribute to the fight against tax fraud, tax
evasion and aggressive tax planning

2

2

18

The human competency-building / training actions
funded by the Fiscalis programme contribute to the fight
against tax fraud, tax evasion and aggressive tax
planning

1

9

12

Neither agree nor disagree

Tend to agree

Fully agree

Source: Economisti Associati study - NFC consultations (Number of respondents: 22) 

Although secondary evidence on effects on tax fraud, tax evasion and aggressive tax planning is rather 
scarce, the case studies considered for this evaluation provide more detail on how this impact has 
been achieved in practice.  

The detection of VAT fraud is  the main objective of the  TNA. The system  helped to  make  fraud 
detection  quicker  and  more  accurate,  thanks  to  signals  regarding  potential  fraudsters  being  more 
targeted and precise than the manual exchanges that had occurred before the system was in place. 
Evidence collected confirmed that since its introduction the system led to the identification of 12 000 
fraudulent  traders  and  to  the  de-registration  for  VAT  of  6  000  suspicious  traders.  Furthermore,  it 
allowed the uncovering of nearly EUR 34 billion in suspicious transactions between 2021 and 2023, 
and  led  to  the  prevention  of  fraud  (unquantifiable  but  likely  significant)  thanks  to  the  early 
identification  of  fraudsters  and  to  their  reduced  amount  of  time  they  can  operate  before  being 
discovered.  These  indicators  have  increased  over  the  years  since  the  introduction  of  TNA,  likely 
thanks  to  better  targeting  of  the  qualification  activities  and  an  increased  number  of  overall 
qualifications. 

The DAC6 CD has the ultimate objective of providing tax authorities with high-quality and up-to-
date information on risky cross-border arrangements, with the threefold purpose of: (i) identifying 
and  closing  legislative  loopholes;  (ii)  feeding  into  audits  and  tax  controls;  and  (iii)  deterring  tax 
evasion and avoidance. Most tax authorities (23 out of 27) have started using the information received 
for risk assessment and tax audits.  

36 Refer to Annex V for a more in-depth overview of the consultation activities. 

28 

 
 
 
 
 
The  EMCS  has  the  overarching  aim  of  combating  excise  duty  fraud  and  making  commercial 
movements of excise goods more secure by replacing the pre-existing, paper-based system with IT-
based  operations.  In  doing  so,  the  EMCS  has  improved  tax  authorities’  ability  to  monitor 
consignments’ movements in real time, including through improved coordination with other Member 
States. The latest innovation introduced in the EMCS succeeded in reducing fraud and illicit trade, 
although precise estimates are generally not available. The system had a pre-emptive impact, acting 
as  a  deterrent  to  fraudulent  behaviour,  as  traders  know  that  it  allows  real-time  verification  of 
consignments. In addition, the direct experience of tax authorities suggests that the digitalisation of 
paper-based procedures has contributed to a noticeable – although hard to quantify – impact in terms 
of fraud reduction, particularly as regards duty-paid B2B fraud.  

The VoW was created to simplify the verification of business partners’ VAT numbers, which is a 
requirement  for  businesses  and  important  for  preventing  VAT  fraud  in  cross-border  transactions. 
While the primary objective of the system  is  to minimise  the administrative burden for  economic 
operators  when  complying  with  this  obligation,  the  system  also  aims  to  reduce  both  involuntary 
mistakes and, ultimately, fraudulent behaviour.  The reliability and very extensive, growing use of 
VoW by businesses, shows its vital role in this task, which was confirmed by interviews and large-
scale survey (about 1,300 respondents) conducted in the context of this evaluation37. Interviewed tax 
authorities also agreed that VoW helps reduce VAT fraud and further emphasised that the system 
helps them identify fraudsters. 

Efficiency 

The assessment of the efficiency criterion looks at the programme's benefits in relation to its costs to 
determine  whether  it  has  been  cost-effective.  In  this  regard,  the  Fiscalis  monitoring  framework 
explicitly mentioned the imperative to foster ‘more efficient tax authorities’ (result 3). The analysis 
below looks at the extent to which the programme’s budget  (EUR 269 million between 2021 and 
2027)  has been spent efficiently so far (i.e. halfway through the funding period) on the activities that 
it supports. 

In line with the broader evaluation approach, the first efficiency-related question focuses on the costs 
and benefits of the EESs (and their central components) funded under the Fiscalis programme. To 
answer this question, the evaluation will draw mainly on the four IT case studies by highlighting both 
the similarities between them, as well as key findings for the individual systems. The following strand 
will draw on the LMS case study to investigate the efficiency of the non-EES components, including 
training activities, collaborative actions, the LMS, e-learning and common learning events. Lastly, 
this section will also deal with the efficiency of overall programme management and governance. 

37 In a short survey launched on the VoW interface to assess the added value of the system, the majority of the respondents 
(65%) reported to only use VoW to verify VAT numbers from MS other than their own. 48% reported that the VoW 
is more effective than any other tools for verifying VAT numbers and 30% reported it is as effective as other tools for 
verifying VAT numbers. 

29 

 
 
 
 
 
➢  Fiscalis support for the EESs generates cost savings for tax authorities and for economic 

operators 

In terms of costs, the central components of the EESs are by a large margin the most significant 
part of the Fiscalis programme, accounting for on average over 83% of the Fiscalis budget between 
2021 and 2024, with  commitments in the order of EUR 30-35 million per year since 2022. These 
expenses cover the costs for all stages of IT systems development, from design and specification to 
development, implementation, maintenance and quality control.  

Figure 10. EES funding and the Fiscalis budget 

34,5

36,6

34,7

35,2

31,3

38,4

33,6

45
40
35
30
25
20
15
10
5
0

s
n
o
i
l
l
i

M
R
U
E

22,2

2021

2022

2023

2024

EES Funding

Total yearly expenses

Source: Economisti Associati study elaboration from DG TAXUD/APR data  

Information at system level shows that central funding for the 30 EESs funded by Fiscalis is spent 
mostly  on  infrastructure  (typically  over  50%  of  funding)  followed  by  maintenance  and  support 
(between 14-40%), with the smallest share being spent on development (usually one-off costs).  

The four IT case studies covered by the external study supporting this evaluation are the principal 
source of evidence for investigating the extent to which cost savings and tangible benefits have been 
achieved for stakeholders impacted by Fiscalis. As further detailed in Annex II, the cost and benefits 
of the current situation were assessed and demonstrated using a series of counterfactual scenarios. 
The  evidence  collected  was  then  compared  with  a  plausible  hypothetical  scenario  where  no  EU 
funding (via Fiscalis) was available for the systems in question. Depending on the specifics of each 
system, and whether or not the system is the direct or indirect result of a legal obligation that requires 
the  electronic  exchange  of  data,  the  counterfactuals  for  each  system  are  framed  differently,  e.g.  
‘simply’  returning  to  the  situation  before  the  system  was  launched,  or  using  more  rudimentary 
systems or systems developed mainly at national level, without EU support. 

The case studies show that TNA, VoW and EMCS have generated significant tangible benefits 
and  cost  savings  for  tax  authorities,  the  European  Commission  and  economic  operators.  These 
benefits include substantial time and resource savings from automating previously manual processes, 
reduced  waiting  times  for  commercial  activities,  and  both  direct  and  indirect  impacts  on  fraud 
reduction.  The  case  for  cost  effectiveness  is  less  certain  for  DAC6,  the  benefits  of  which  were 
harder to isolate and quantify. This is partly because the system was introduced recently, and its aim 
is  less  fraud  detection  (relatively  easy  to  measure)  than  fraud  prevention  (which  is  by  nature  less 

30 

 
 
 
 
countable).  While  the  exact  quantification  varies  across  different  systems,  the  case  studies 
demonstrate that the benefits generally outweigh the costs.  

Evidence  of  the  efficiency  gains  achieved  through  an  IT  system  automating  previously  time-
consuming processes was collected via the case studies. Such processes include the collection and 
processing of data by the TNA, the verification of eADs through EMCs and the automatic extraction 
of statistics from  DAC6, all of which previously required significant  staff and time resources. By 
digitalising  these  processes,  tax  authorities  are  able  to  unlock  productivity  gains  and  commit 
resources to more highly skilled and productive tasks, such as IT development or identifying fraud.  

The  same  applies  to  economic  operators  who,  thanks  to  the  EESs  and  the  digitalisation  of  key 
compliance processes, can save and redeploy resources. Another key similarity across some of the 
case studies is the somewhat unquantifiable benefit of reduced waiting times which, in turn, supports 
and  increases  the  efficiency  of  commercial  activities.  Waiting  times  are  not  a  direct  cost,  but  if 
economic operators did not have access to these systems, they would have to wait for a VAT number 
to be checked or a disrupted EMCS movement to be closed, which would prevent them from moving 
forward with  various business operations. These protracted waiting  times can  result in  significant 
opportunity costs that prevent businesses from devoting their time to productive activities like sales 
or production.  

Finally, it should also be noted that these benefits should be considered alongside others generated 
by the EESs, such as direct and indirect reductions in fraud.  

Table 3. Summary of the costs for the EES case studies 

IT system 

TNA 

VoW 

EMCS 

DAC6 

Costs (total between 2021 and 2023) 
Central (EU) costs  

EUR 6.97 million 

Member State costs   N/A 

EUR 8.2 million 

EUR 12.39 million 

EUR 1.93 million 

~EUR 5 000 – 50 000 
for 
developing 
national  systems  and 
an  annual  cost  of 
EUR 5 000 
for 
maintenance 

EUR 1.75 million 

N/A 

50 000-
for 
and 
an 
and  ~EUR 
for 

~EUR 
220 000 
developing 
implementing 
update 
30 000-60 000 
maintenance 

Between 1 FTE for an 
SME and EUR 60 000 
per 
for 
year 
contracting  a 
third-
party provider 

Economic  operator 
costs 

N/A 

N/A 

Benefits  

Quantifiable benefits  

31 

 
 
 
IT system 

TNA 

VoW 

EMCS 

DAC6 

~3-6  FTEs  saved  for 
IT  development  and 
maintenance 

~1 FTE saved per MS 
for 
verification 
activities. 

~  1.5  staff  days  per 
tax 
year  saved  per 
administration 
for 
compiling statistics  

Significant 
cost 
savings  for  feedback 
and status messages 

Negligible  impact  of 
less 
homogenous 
quality of information 
which  arrives  more 
quickly  

Variable costs related 
to the compilation and 
processing 
of 
incoming information 

~750  and  1 500  staff 
through 
days  saved 
automation  of 
the 
paper-based 
B2B 
duty-suspended 
movements 

~120  staff  days  spent 
for 
on 
waiting 
be 
movements 
closed saved per MS 

to 

~1 FTE saved through  
sending  and  receiving 
eADs automatically 

Linking  EMCS  and 
EOs 
AES 
saved 
in  export 
engaging 
~12 staff days per year   

MSs 
the 
avoid 
significant  cost  of 
having  to  set  up  a 
bilateral  IT  exchange 
with 
other 
every 
Member State 

in 

Reduction 
the 
significant  cost  of 
disruption  caused  by 
for 
waiting 
movements 
be 
closed  

to 

saved 

~7 staff days per month 
for 
per  MS 
and 
collecting 
data, 
processing 
corresponding to some 
EUR  1.7  million  per 
year overall 

Suspicious transactions 
amounting 
to  nearly 
EUR 34  billion  were 
uncovered 
between 
2021 and 2023 

Member States 

Economic 
operators 

~1-3  FTEs  saved  for 
support 

Large 
companies 
saved  ~52  staff  days 
for  checking  VAT 
number 

Small 
companies 
saved  ~1-2  FTEs  and 
large companies saved 
~3-5 
for 
FTEs 
verification 

Non-quantifiable benefits  

Member States 

Significant time saved 
on 
bilateral 
interactions,  such  as 
requests 
for 
qualifications 

avoid 

the 
EOs 
significant 
cost 
scenario  of  having  to 
develop 
their  own 
systems  

Carrying out fraud/pre-
anti-fraud 
emptive 
as 
such 
measures, 
blacklisting 
a 
had 
significant  impact  on 
fraud deterrence 

Economic 
operators 

Source: Economisti Associati study 

avoid 

the 
EOs 
negligible 
potential 
cost  of  contracting  a 
third-party 
provider 
for  VAT  verification 
and updating APIs for 
batch requests  

32 

 
 
 
 
 
 
 
 
 
Cost effectiveness of EESs 

Comparing the costs and benefits of the four systems assessed in the case studies allows the following 
inferences to be made regarding cost effectiveness38: 

   For  TNA,  the  time  savings  compared  to  the  counterfactual  scenario  can  be  quantified  at 
approximately seven staff days per month for each tax administration, resulting in cost savings of 
around EUR 1.7 million between 2021 and 2027. This estimate may be reductive, as it does not 
take into account, firstly, the amount of time saved by Eurofisc working field coordinators when 
managing exchanges of information and aggregating data, which is likely considerable. Secondly, 
it does not take into account the savings related to requests for qualification, notifications and 
other bilateral interactions. These are now carried out on the TNA directly and would take longer 
to carry out by other means, though, as mentioned above, interviewees were not able to quantify 
these.  

   For VoW, centralising VAT number verification through a platform funded by the Commission 
has resulted in significant cost savings. The time savings compared to the counterfactual scenario 
(which  would  entail  national  systems  being  made  accessible  to  economic  operators  from  all 
Member States) can be quantified at some 120 staff days per month for each administration. This 
assumes that each administration would otherwise need to hire four staff members dedicated to 
developing and maintaining  the platform,  and two staff members to  manage the helpdesk  and 
troubleshooting support for VoW users. Across the EU, this translates to approximately 162 full-
time equivalents (FTEs) and total annual salaries of approximately EUR 7 909 24539. This reflects 
significant  time  and  resource  savings  compared  to  the  counterfactual  scenario,  where 
development, maintenance and support costs fall to Member States. Due to the hypothetical nature 
of the costs, these estimates involve a significant degree of uncertainty. Nonetheless, they give an 
approximate indication of the additional costs that MS authorities might incur in the absence of 
VoW. VoW has also resulted in significant cost savings for economic operators in areas such as 
resource allocation (human and time), VAT verification costs, batch requests and API integration 
costs, including  quantified estimates of the actual  savings generated. This  results in  combined 
savings of between EUR 39 and 84 million for tax authorities and economic operators, depending 
on company size, with average savings of EUR 61 million and a cost/benefit ratio of 7.5. It is 
important to note that these estimates are based on qualitative feedback collected in interviews, 
and actual cost savings may vary significantly. 

   For EMCS, Fiscalis funding for the central SEED likely results in minimum savings of one FTE 
each  per  tax  authority  and  medium/large  economic  operator,  compared  to  the  counterfactual 
scenario. By contrast, the system and the related electronic data requirements mean that a small, 
undigitised  company  might  need  to  hire  one  FTE.  The  savings  generated  by  the  other  central 
components  are  evident  but  less  certain  (for  instance,  ACO,  which  aims  to  facilitate  better 
communication  among  tax  authorities,  is  likely  to  reduce  waiting  times).  All  in  all,  while  the 
development  and  adjustment  costs  for  both  Member  States  and  economic  operators  are 

38 Please refer to Annex IV for a more detailed overview of the costs and benefits generated by EESs. 

39 Annual cost set at the average EU27 hourly wage for professionals (Eurostat, Mean annual earning by sex, age and 

occupation – NACE Rev. 2, B-S excluding O), plus 25% overheads. 

33 

 
 
 
significant, they are likely lower than costs that would have been incurred otherwise. Importantly, 
several  of  the  updates  assessed  in  the  case  study  were  introduced  to  solve  problems  affecting 
specific  parts  (and  stakeholders)  of  excise  trade,  meaning  that  the  benefits  are  not  universally 
observed (while the costs are much more direct and clearly felt). However, even those updates 
appear to be cost-effective. For instance, despite the low percentage of B2B duty-paid movements 
as  a  share  of  total  excise  movements,  the  added  value  of  phase  4.0  is  clear  in  the  eyes  of 
stakeholders, particularly in terms of fraud prevention.  

   For DAC6, cost-benefit analysis is prevented by the fact that quantifiable benefits from DAC6 still 
need to emerge. Furthermore, cost savings (in comparison with the counterfactual scenario) could 
not  be  quantified  due  to  the  wide  variety  of    replies  provided40.  Nonetheless,  some  general 
considerations  can  be  drawn.  On  the  one  hand,  it  is  not  clear  to  what  extent  DAC6  CD  led  to 
adjustment costs for tax authorities being lower than would be expected under the counterfactual 
scenario.  On  the  other  hand,  it  appears  that  the  system  results  in  lower  administrative  costs  in 
comparison  with  the  counterfactual  scenario,  thanks  to  the  absence  of  feedback  and  status 
messages,  and  the  automatic  extraction  of  statistics.  Finally,  cost  savings  are  higher  for 
administrations  that  would  not  be  able  to  automate  their  processes  under  the  counterfactual 
scenario: smaller administrations, or those with fewer resources for IT development, need to rely 
more on manual processes, and thus benefit more from the CD. 

➢  The budget for collaborative actions and training activities is relatively small but, given 

their added value, they can be considered cost-effective 

The Fiscalis programme funds several activities related to human competency building and training, 
including ‘common learning events’ (CLEP) and, crucially, the Customs and Tax EU Learning Portal 
(referred to as the LMS). The LMS acts as the common platform for disseminating e-learning modules 
and organising CLEP training sessions funded by the Fiscalis and Customs programmes.  

Spending on training activities between the beginning of the programme in late 2021 and mid-2024 
was a little over EUR 0.5 million, as shown in the figure above, which does not include the cost of 
the LMS platform (discussed separately below). According to ART data, this translated into just over 
2 400  training  activities.  The  vast  majority  of  these  have  been  for  IT  systems  training  (1 638), 
followed by CLEP events related to the AIAC community (651), newcomer training for tax recovery 
assistance  (98)  and  online  CLEP  ‘train  the  trainer’  training  events.  The  average  per-training  cost 
fluctuated slightly over the past three years (2022: EUR 226; 2023: EUR 231) but saw its lowest cost 
in 2024 at EUR 223 per training event over the course of 666 separate activities. While these statistics 
provide a sense of the value of the training activities, there was little feedback from the stakeholders 
as to their cost effectiveness. 

Extent to which the learning management system is cost-effective 

Figure 11 below presents  spending  on the LMS  until 2024, including for the two years before the 
current programming period, when the initial development work had already begun. As shown, just 

40 Please refer to Annex V for a detailed overview of the consultation activities carried out during the evaluation. 

34 

 
 
 
 
 
over EUR 1.5 million has been spent on the LMS to date, which is shared between the Customs 
and  Fiscalis  programmes.  As  expected,  most  of  it  (74%)  has  been  devoted  to  development  costs 
(including  a  significant  investment  in  security  measures  in  2024),  while  14%  has  gone  on 
maintenance and support, with the remaining 12% on hosting the portal. As mentioned above, the 
technical developments and operation of the LMS are outsourced to an external contractor, following 
a competitive procurement process.  

Figure 11. Spending on the LMS from 2019-2024, EUR  

600.000

500.000

400.000

300.000

200.000

100.000

0

2019

2020

2021

2022

2023

2024

Hosting

Development

Maintainance and support

Source: Economisti Associati study elaboration from DG TAXUD data  

Despite  the  absence  of  set  targets  or  benchmarks,  some  considerations  concerning  the  cost 
effectiveness of the LMS can also be made. Hence:  

   Spending on the LMS accounts for less than 1% of overall expenditure, meaning that it is not 

a major cost driver for the Customs and Fiscalis programmes.  

   Stakeholders have emphasised the quality of the LMS, and of the processes for developing it 
and for ongoing improvements and support. This suggests that the work is not only meeting, 
but also exceeding, expectations, which is a key pre-condition for efficiency.  

   On the other hand, the Member States generally maintain their own LMSs and run the e-learning 
courses  using  those.  The  EU  LMS  has  therefore  not  yet  replaced  other  infrastructure.  Such 
replacement would be needed to generate larger-scale savings and economies of scale. Moreover, 
while some Member States promote the EU LMS (e.g. through links on their national LMS and 
in training guidance), the relatively small number of users, especially in terms of those taking 
courses directly on the LMS or via the LTI functionality, indicates untapped potential. 

Extent to which other activities are perceived as cost-effective  

Collaborative actions are implemented on the basis of grant agreements between the Commission 
and the applying administrations, which are represented by a grant coordinator. These actions must 
be aligned with the programme’s legal scope and objectives. Furthermore, each action has a dedicated 
action manager, who leads and coordinates the activity with various powers, including the ability to 
terminate the participation of a representative, e.g. due to lack of engagement. These individuals are 
subject to oversight by the Commission, which must be informed of any change in action manager. 

35 

 
 
 
 
Thus far (2021-2024), just over EUR 11 million of Fiscalis funding has been spent on collaborative 
actions (including expert teams). 

Feedback from beneficiaries (national tax authorities) confirms that collaborative activities (including 
expert teams in the right circumstances and on the right topics) continue to be seen as highly effective 
and relevant. And, since the funding modalities have remained unchanged (with the single exception 
of the grant management model, discussed below), these activities can still be considered to be cost-
effective overall. There is a slight reduction in  face-to-face meeting time and in the trust-building 
and  networking  effects  this  tends  to  generate,  meaning  that  it  is  not  possible  to  conclude  that 
collaborative activities have become more cost-effective than under the previous programme.  

Coherence 

The  external  coherence  of  the  Fiscalis  programme  was  assessed  positively  in  previous  evaluation 
exercises. Looking at the two most recent evaluations, the final evaluation of Fiscalis 2020 found the 
programme  to  be  ‘coherent  and  consistent  with  EU  priorities  and  complement  other  funding 
programmes’,  while  the  mid-term  evaluation  found  ‘strong  evidence  of  external  coherence, 
underpinned by the programme’s consistency with the Europe 2020 Strategy (the key policy reference 
of  the  time)  and  the  involvement  of  third  countries  (in  light  of  EU  enlargement)’.  This  broad 
consistency  was  hardly  surprising,  given  that  the  Fiscalis  programme  exists  to  support  the 
development and implementation of EU tax policy, which is itself aligned with other policies and 
programmes. 

➢  Other EU policies and interventions have accelerated progress towards the Fiscalis objectives 

Over the last decade, the EU has experienced a policy and cultural shift when it comes to tax 
fraud, tax evasion and aggressive tax planning. New tax policies aimed at increasing fairness and 
transparency in EU tax systems have been implemented, international cooperation has been increased 
and  minimum  standards  have  been  drawn  up,  also  in  line  with  international  developments,  for 
instance at  OECD level41. The  external  coherence of the Fiscalis  programme has always been 
assessed positively. For instance, the final evaluation of Fiscalis 2020 found the programme to be 
‘coherent and consistent with EU priorities and complement other funding programmes’.  

Concerning the alignment between the programme and other initiatives, the objectives of Fiscalis 
are aligned with the Union anti-fraud programme (UAFP, managed by OLAF). The two actions are 
highly  complementary,  with  minimal  risk  of  duplication  or  overlapping.  However,  practical 
cooperation and synergies were limited, which meant that the potential for increased coordination 
could not be fully exploited. Fiscalis objectives are also consistent with, and often mutually reinforce, 
those of other initiatives, such as the Recovery and Resilience Facility (RRF) and related Technical 
Support Instrument (TSI) (both managed by SG REFORM), and the European Green Deal. 

41 This includes the BEPS (Base Erosion and Profit Shifting) 1.0 initiative, launched in the early 2010s, comprising 15 
actions, most of which have been enacted within the EU by means of a Directive (including notably several DACs). 
More recently, the OECD Pillar II initiative has been implemented within the EU through Council Directive (EU) 
2022/2523 of 14 December 2022 on ensuring a global minimum level of taxation for multinational enterprise groups 
and large-scale domestic groups in the Union. 

36 

 
 
 
 
Clear links  also  exist  between  Fiscalis  and the  initiatives above, the purpose being  to  exploit the 
cross-cutting benefits of digitalisation. For example, the APRs highlight, among other things, how 
Fiscalis activities were used to raise awareness of the TSI project on digitalisation of tax and customs 
administrations42 and of other opportunities for support. This in turn fed into the recovery plans of 
individual Member States. Many of the e-learning courses also help tax administrations and economic 
operators to adapt to new digital processes, such as the One-Stop Shop introduced as part of the e-
commerce package. While not mentioning wider policies by name, the digitalising effect of many 
Fiscalis IT projects, including those examined for the case studies, is self-evident. In addition, the 
2024 APR refers to Fiscalis project groups providing input to TSI projects on  a number of topics:  
exchanging data under DAC, simplification measures for businesses, implementing digital reporting 
requirements in the field of VAT and minimum corporate income tax rules43. 

Regarding  green  policies  specifically,  the  2021-2023  MAWP  mentions  revising  the  Energy 
Taxation  Directive,  and  the  importance  of  digitalisation  for  achieving  sustainability  goals.  Both 
aspects are also mentioned consistently in the APRs, with digitalisation initiatives getting particular 
emphasis.  

For  other  relevant  initiatives,  such  as  DG  GROW’s  single  market  programme  and  DG  ENEST’s 
instrument for pre-accession assistance and technical assistance and information exchange (TAIEX), 
practical coordination started only after the candidate countries became fully operational under the 
Fiscalis programme in 2024.  

➢  Awareness of the contribution of Fiscalis is generally sufficient, but support for EESs is less 

visible  

There is generally a sufficiently high level of awareness of Fiscalis activities and achievements 
across tax authorities. Around 90% of the national coordinators consulted for this evaluation were 
satisfied with the way information on the programme is disseminated within their administrations. 
Similarly, in their yearly survey, national coordinators reported that the level of knowledge of the 
programme  across  their  administrations  is  adequate.  While  awareness  tends  to  be  higher  among 
experts  participating  actively  in  Fiscalis  initiatives,  all  officers  have  a  basic  familiarity  with  the 
programme  and  can  easily  access  information  if  and  when  needed.  A  deeper  knowledge  is  not 
considered necessary.  

42 See more information in the summary fiche here. 
43 Fiscalis Annual Progress Report 2024 

37 

 
 
 
 
Figure 12. Satisfaction with dissemination of information on Fiscalis programme 

How satisfied is your administration with how the European 
Commission disseminates information about the Fiscalis programme?

Fully satisfied
6

Neither satisfied 
nor dissatisfied
2

Mostly satisfied
14

Source: Economisti Associati study elaboration on NFC consultations (number of respondents: 22) 

While there is generally a high level of awareness regarding collaborative actions, the visibility of 
programme funding for EESs appears more variable. Over one third of NFCs consulted for the 
study reported that tax officials in their administrations  had only a limited awareness of which IT 
systems  are funded by the Fiscalis programme. However, awareness  is  reportedly  increasing  over 
time, also thanks to the efforts of the coordinators themselves.  

No particular concerns were raised regarding the extent to which senior management and decision 
makers are aware of the programme. In this respect, the role of TADEUS is particularly praised 
for its contribution to increasing the engagement of tax administration management in the programme 
and for increased knowledge of the programme’s benefits and role44. 

➢  MEF and issues with assessing the impact of the Fiscalis programme 

The current MEF of the Fiscalis programme, introduced in 2022 for the current funding period, has 
the overall purpose of ensuring ‘the effective assessment of the Programme’s progress towards the 
achievement of its objectives’45. The MEF presents the programme’s intervention logic and identifies 
a set of 38 indicators that have the purpose of tracking the information needed for the assessment. 
Some of the indicators are laid down in the Fiscalis Regulation, or stem from the reporting obligations 
laid down therein, while others have been established separately. In particular:  

   The  MEF  includes  no  less  than  20  output  indicators,  several  of  which  are  only  partially 
informative. This is due to either lack of clarity or underlying issues in the data sources. This 
is particularly the case for indicator ‘OP 2.2.2 – number of professionals trained’, since the 
information comes from different sources (the LMS itself and national tax authorities) that 
lack a uniform approach/interpretation. 

44 Please refer to Annex V for a complete overview of the consultation activities carried out for the evaluation. 
45 Commission staff working document – Monitoring & evaluation framework for the Fiscalis programme (2021-2027), 

p. 2. 

38 

 
 
 
 
 
 
 
   The  14  results  indicators  have,  overall,  been  useful  for  assessing  the  performance  of  the 
programme for this evaluation, particularly when it comes to the indicators that clearly link 
the  programme  to  progress  towards  specific  objectives.  Other  indicators,  however,  are 
affected by similar issues to those described above under outputs.  

   Finally,  of  the  four  impact  indicators,  only  one  provides  information  on  the  results  of  the 
Fiscalis  programme  activities  (i.e.  the  contribution  of  administrative  cooperation  (and 
particularly of DAC) to  protecting the financial interests of the Member States). The other 
three indicators, which mostly draw on macro-level indicators, are more useful for providing 
context than for monitoring the developments supported by the programme. 

Further simplification, streamlining and targeting of the MEF appears necessary. Three main areas 
for potential improvement can be identified:  

▪  Minimise  the  amount  of  primary  data  collection.  When  consulted  for  this  evaluation, 
national coordinators reported that tax officers were experiencing considerable ‘consultation 
fatigue’ with regard to the number of surveys and consultations related to the programme.  

▪  Exploit existing data to obtain indicators that provide better insight into the achievements of 
the programme. For example, information could be included on the results obtained by the 
TNA, which are already reported in the TNA statistics.  

▪  Reduce  the  number  of  indicators  under  the  MEF,  particularly  at  output  level.  Fewer, 
targeted  indicators  could  be  easier  to  digest  for  stakeholders,  while  reducing  the  effort 
required for data collection and reporting.  

➢  The synergies between the IT systems and collaborative actions are significant and widely 

evident, but a lack of mutual awareness hinders coherence 

As discussed in the section above, the significant synergies between the two ‘pillars’ of the Fiscalis 
programme, namely support to IT systems and collaborative actions, are evident. Collaborative 
actions have a crucial role in supporting the development and, in some cases, operation of the systems. 
The case of TNA is emblematic: besides supporting the development of this IT system, the Fiscalis 
programme  funds  the  TNA  expert  team,  which  brings  together  the  system’s  users  and  plays  an 
important role in how the system is developed and integrated into the activities of tax authorities. 
Based on the feedback collected from Eurofisc officials, including expert team members, it would be 
virtually impossible for the Member States to allocate the human resources needed for this purpose 
on their own without the programme’s funding. The situation was similar for the IT systems examined 
in the other case studies, and across the programme’s different strands of activity. To give an example, 
in the field of capacity building, most e-learning courses serve either to support the implementation 
and application of EU law, or to support the use of specific programme-funded IT systems.  

Overall, as found in previous evaluations, the actions funded by the Fiscalis programme not only add 
value in their own right, but act together to support the uniform implementation and uptake of 
EU tax policy. Both these aspects are essential to achieving the objectives of the programme. In this 
way, the programme’s different strands of activity complement and mutually reienforce each other, 
and are therefore highly internally coherent. 

39 

 
 
 
Any  issues  that  were  identified  related  to  communication,  visibility  and  awareness.  More 
specifically,  although  IT  systems  account  for  over  80%  of  the  Fiscalis  programme  budget, 
stakeholders in the Member States tend to think of ‘the Fiscalis programme’ as the collaborative and 
capacity-building actions. They are only vaguely aware that the IT systems are formally part of the 
same programme (though it is common knowledge that they are supported with EU funding). The 
evaluation did not assess internal coherence in depth and thus cannot draw firm conclusions on the 
consequences of this fact. Still, it may be worth developing a holistic ‘brand’ for the programme to 
ensure that opportunities for synergies are grasped and the full value of the programme is  widely 
understood. 

4.2. How did the EU intervention make a difference and to whom? (EU added value) 

EU added value means the changes brought about by the Fiscalis programme which are additional to 
those  that  could  be  reasonably  expected  from  Member  State  action  alone.  Previous  evaluations  have 
consistently found the programme’s EU added value to be high, based on its supporting – and often 
catalytic – role in tax policy development and implementation. The final evaluation of Fiscalis 2020 
highlighted the EU added value of all the main programme components, including the IT systems 
(‘which  are  crucial  to  ensuring  the  availability  and  sharing  of  information’),  the  collaborative 
activities  (previously  known  as  joint  actions  and  which  gave  ‘the  administrations  unequalled 
opportunities  for  cooperation,  communication  and  networking’)  and  the  training  activities  (which 
‘helped  national  tax  administrations  better  understand  and  implement  EU  tax  legislation  and  its 
related procedures in a more uniform manner’ and improved ‘‘officials’ ability to work with the IT 
systems’).  

As already discussed, the programme has made a difference, in the first instance, to the users of the 
IT systems (EESs) that are supported from the programme’s budget. These include the national tax 
administrations of the EU Member States, who use the various systems both to collect and exchange 
data and information and (especially in the case of the de-centralised systems) to ensure the systems 
are interoperable with the relevant national components. They also include economic operators, who 
are direct or indirect users of many of the IT systems in question.  

The  collaborative,  human  competency-building  and  training  activities  under  the  Fiscalis 
programme have also made a significant difference to the national tax administrations of participating 
countries  –  including  EU  Member  States  and  the  third  countries  that  signed  an  agreement  to 
participate in the Fiscalis programme. More indirectly, these activities can benefit economic operators 
and even  the wider public, to  the extent that  the programme activities can help  to  effectively  and 
efficiently  implement  EU  policies  and  legislation  that  aim  to  reduce  tax  fraud,  tax  evasion  and 
aggressive tax planning.  

The feedback from national tax administrations via the survey regarding the overall value added of 
the Fiscalis programme is overwhelmingly positive. As shown in Figure 13 below, the majority of 
respondents reported that, ‘to a great extent’, the programme builds trust and leads to convergence 
between participating tax administrations; helps to apply EU rules more effectively, consistently and 
uniformly; and means EU legislation is implemented more quickly than would be possible without 
Fiscalis. Responses were a little more nuanced as regards the question of whether the programme 

40 

 
 
 
adds value above and beyond initiatives at national level, without any duplication and overlap. Even 
so, over 90% of respondents believed it does so to a greater or lesser extent. In response to follow-up 
questions, respondents reported that the Fiscalis programme has had a significant impact on efficiency 
and international cooperation, particularly by developing and implementing IT systems like VIES, 
and projects such as VAT in the Digital Age, both of which were mentioned by multiple respondents.  

Figure 13. Fiscalis added value for national administrations 

Build trust and lead to convergence between the tax
administrations of participating countries

Apply EU rules more effectively, consistently and
uniformly

Implementat EU legislation/ rules more quickly than
would have been possible without the Fiscalis
programme

Adds value above and beyond initiatives at national
level, without duplication or overlap

20

18

18

10

2

4

3

1

1

1 1

20

9

15

10

5

0

To a great extent

To some extent

To a small extent

Not at all

Not sure/ I don't know

Source: Economisti Associati study elaboration on NFC consultations  

During  interviews,  representatives  of  national  tax  administrations  reported  that  the  Fiscalis 
programme creates added value primarily by: 

   facilitating  the  implementation  of  EU  law  and  harmonisation:  Fiscalis  is  crucial  for 
implementing EU directives and ensuring that laws are applied consistently across Member 
States, particularly in areas like VAT and digital taxation.  

   enhancing  collaboration  and  knowledge  sharing:  the  programme  fosters  collaboration 
through collaborative actions such as expert teams and workshops, during which best practices 
are shared.  

   supporting  digitalisation,  and  developing  and  implementing  IT  systems:  Fiscalis 
contributes  to  the  digitalisation  of  tax  administrations  by  developing  the  EESs,  as  well  as 
through expert teams focused on areas like CESOP.  

   strengthening  administrative  capacity:  by  providing  training,  expert  support  and 
opportunities  for  collaboration,  the  Fiscalis  programme  strengthens  the  administrative 
capacity of national tax administrations. This enables them to implement EU legislation and 
manage complex tax issues more effectively. 

➢  Added value of the different programme activities 

The evidence collected and analysed by this evaluation (see also Sections 4.1 and 5.3) confirms that 
the  EU  added  value  of  all  the  different  types  of  activities  funded  by  the programme  (IT  systems, 

41 

 
 
 
 
training and capacity-building actions, expert teams and collaborative activities) is high. However, 
there are some nuances and specific circumstances, which are briefly outlined below. 

IT systems 

The  Fiscalis  programme’s  support  for  developing,  maintaining  and  upgrading  IT  systems 
(specifically the common components of the EESs) accounts for most of the programme’s budget. It  
is  hugely  significant  in helping  the digital exchange of information to  function properly  in  a 
number of areas, in many of which it is mandated by EU legislation. 

The in-depth case studies on four IT systems (TNA, DAC6, VIES-on-the-web and EMCS) confirm 
the high EU added value of each of these systems, and specifically of the Fiscalis programme as a 
key enabler. An explicit counterfactual scenario was developed: how would EU tax administrations 
and economic operators exchange the relevant data and comply with their obligations if there was no 
EU funding for the relevant components of the systems in question? The case studies demonstrate 
that, in each case, without  the  Fiscalis  programme  funding, there would be higher costs  and 
lower  benefits  (some,  but  not  all,  of  which  can  be  estimated  quantitatively)  for  national  tax 
administrations and, in the case of VIES-on-the-web and EMCS, also for economic operators who 
use these systems.  

Collaborative activities 

Based  on  the  feedback  received  from  Member  State  tax  administrations  (via  the  survey  and 
interviews), the collaborative activities are the most widely and consistently appreciated of the 
various  types  of  Fiscalis-supported  activities.  82%  of  survey  respondents  ‘fully  agreed’  that  the 
collaborative  activities  contribute  to  the  fight  against  tax  fraud,  tax  evasion  and  aggressive  tax 
planning,  and  73%  ‘fully  agreed’  that  they  correspond  to  the  needs  of  EU  tax  administrations 
(significantly  more  than  for  the  IT  systems  and  competency-building/training  actions).  The  vast 
majority (82%) also  reported  that they found the collaborative activities  ‘very useful’, while 14% 
described them as ‘useful’, and only one respondent thought they were ‘not very useful’. 

During  interviews,  representatives  of  national  tax  administrations  highlighted  the  following  key 
aspects  of  added  value  that  specifically  related  to  collaborative  activities  within  the  Fiscalis 
programme: 

   Improved implementation of EU law and policy goals: this was particularly evident in areas 
like the DAC, ViDA and CESOP initiatives. Collaborative efforts reportedly help ensure that 
rules across Member States are applied consistently and facilitate the practical application of 
complex regulations. 

   Improved cooperation and coordination: beyond simply implementing rules, collaborative 
activities fostered a sense of shared purpose and improved coordination among national tax 
administrations.  This  included  sharing  best  practices,  developing  common  strategies  and 
aligning  national  initiatives  with  EU  frameworks.  The  improved  communication  and 
coordination were seen as crucial for addressing complex, cross-border tax challenges. 

   Increased efficiency and effectiveness: by working together, Member States could leverage 
each  other’s  expertise  and  resources,  leading  to  more  efficient  and  effective  outcomes. 

42 

 
 
 
Examples included bilateral projects and developing joint approaches to common challenges. 
This collaborative approach was thought to maximise the impact of the programme and help 
ensure that resources were used effectively. 

Expert teams 

Expert teams are a specific sub-type of collaborative actions that pool resources across Member 
States. They are used primarily to support the development and implementation of digital taxation 
systems.  Due  to  their  specific  nature,  they  require  dedicated  grant  agreements,  and  the  long-term 
commitment of the experts involved. Unlike other collaborative actions, the programme funds the 
salary costs of the officials involved, with a view to enabling the extensive collaboration required. 

At the end of 2024, there were five expert teams funded by the Fiscalis programme (two others were 
finalised  in  2021).  Some,  but  not  all,  of  these  struggled  with  a  certain  lack  of  commitment  and 
ownership among participating countries (as noted in the  2023 APR), which led to a streamlining 
exercise. Based on the information available in the 2024 APR, and on feedback from national tax 
administrations,  there  appear  to  have  been  significant  differences  between  the  different  expert 
teams in terms of effectiveness and added value: 

   The  Managed  IT  Collaboration  (MANITC  V)  expert  team,  which  supported  digital 
collaboration activities, acting as a secretariat, has completed its task. Because of the above-
mentioned streamlining exercise, it was decided not to launch another iteration of the expert 
team, but to consider transforming it into a project group.  

   The  Transaction  Network  Analysis  (TNA)  and  Central  Electronic  System  of  Payment 
Information (CESOP) expert teams are widely seen as success stories. The 2024 APR notes 
that, ‘in the area of VAT, the ongoing work of the TNA expert team and the CESOP expert 
team represented important added value in the fight against VAT fraud’.  

   For  the  other  two  teams,  they  completed  their  tasks  but  were  not  highlighted  as  particular 
success stories by any consultees. Again, based on the 2024 APR, the development of data 
analysis tool and other solutions for enhanced use of the tax information (DATANA) expert 
team completed the key aspect of its mandate in 2024. Following this, it was ‘decided that the 
work  of  this  expert  team  was  successfully  completed  according  to  the  plan  and  that  there 
would  be  no  need  for  a  prolongation’.  The  Visits  to  Member  States  Directive  on 
Administrative  Cooperation  (VISDAC)  expert  team,  supporting  Member  States  in  the 
effective implementation and functioning of the DAC,  ‘completed all 27 visits to Member 
States during 2023-2024’. 

During  the  consultation,  the  national  tax  administrations  that  provided  detailed  comments  on  the 
added value of the expert teams – in particular the CESOP team – emphasised the practical benefits 
of  expert  team  involvement,  including  access  to  specialised  expertise,  the  opportunity  to  share 
knowledge across borders and the role of the expert teams in developing and implementing IT systems 
related to taxation. 

Thus, overall, it appears that expert teams have the potential to add significant value, but this is 
highly dependent on the specific context and relies, in particular, on whether a sufficient number 
of Member States consider the topic a high enough priority to make the expert team work effectively. 

43 

 
 
The experience of TNA and CESOP suggests that this is more likely to be the case for expert teams 
that directly support the development and/or application of a specific IT system. 

Training activities 

Survey responses from national tax administrations suggest that training activities do add value, 
but not necessarily to the same extent for all Member States. It depends on the resources, priorities 
and materials that are available at national level. 55% of respondents ‘fully agreed’ that the Fiscalis 
programme’s human competency building / training activities contribute to the fight against tax fraud, 
tax evasion and aggressive tax planning (compared with 82% for collaborative activities, and 73% 
for  IT systems).  And 45%  ‘fully agreed’ that the human  competency building /  training activities 
correspond to the needs of EU tax administrations (compared to 73% for collaborative activities and 
41%  for  IT  systems).  It  should  be  noted  that  the  remainder  either  ‘tended  to  agree’  or  responded 
neutrally.  Not  a  single  respondent  disagreed  with  this statement  regarding  any  of  the  activities  or 
systems. 

The case study on the LMS found that, as a whole, the LMS is of high quality and adds significant 
value at a reasonable cost. It improved awareness and uptake of EU training, particularly for training 
coordinators who integrate courses into national curricula. However, some of its features (hosting and 
LTI integration) are more valuable for smaller Member States, which may value the EU LMS due to 
cost savings or enhanced functionality. Larger tax authorities with existing national training platforms 
are less likely to benefit significantly.  

➢  Likely impact of discontinuing the Fiscalis programme 

Many  Member  States  expressed  concerns  and  believed  that  (hypothetically)  discontinuing  the 
programme or reducing the available funding would have negative impacts. Several reported that they 
rely  heavily  on  the  programme  funding,  and  that  reduced  funding  could  lead  to  decreased 
participation, prioritisation of certain activities (often digitalisation) and fewer physical meetings. It 
could potentially hinder the effective implementation of EU taxation policy. Survey respondents were 
also asked to estimate the extent to which they would still be able to participate in collaborative 
activities  if  the  Fiscalis  programme  funding  to  cover  expenses  was  either  reduced  by  50%  or 
eliminated entirely. Under both scenarios, just over half of respondents believed that this would lead 
to  a  major  reduction  in  participation.  The  remainder  expected  a  minor  reduction,  but  a  few 
respondents thought that, without any funding, officials from their country would no longer be able 
to participate in any collaborative actions at all, or would have to limit their participation to online-
only events (which can help save scarce resources, but are less likely to generate the ‘softer’ benefits 
of the programme, in particular trust-building and networking effects)46. 

Thus, the programme as a whole, as well as all of the types of systems and activities it funds, provide 
high EU added value. The Fiscalis programme supports the implementation of EU taxation policy 
and  legislation,  and  encourages  collaboration,  coordination  and  information  exchange  between 

46 Please refer to Annex V for  a complete overview of the consultation activities carried out during the evaluation. 

44 

 
 
 
 
 
 
national tax administrations. This is vital for the effective, efficient and consistent application of the 
EU  taxation  policy,  and  thereby  helps  to  improve  the  functioning  of  the  internal  market,  and  the 
pursuit of a variety of taxation policy objectives. Without the programme, national tax administrations 
would essentially be left to their own devices when it comes to implementing EU taxation policy 
rules and mechanisms. This would very likely be detrimental to all of the aspects outlined previously. 

4.3. Is the intervention still relevant? (Relevance) 

To evaluate the (continued) relevance of the programme, the evaluation looked at two main aspects, 
namely the alignment of the programme’s objectives to the needs and challenges of the EU in the 
field of taxation, and the appropriateness and fitness for purpose of its features and set-up, specifically 
as regards the programme’s support for the common components of the EESs and for collaborative 
activities, training and other actions. 

➢  Alignment of the Fiscalis programme objectives with EU policy needs and priorities 

The Commission’s overall policy priorities in the area of taxation for the period covered by this 
evaluation were set out in a number of documents, most importantly, the 2020 Action Plan for Fair 
and Simple Taxation47 and DG TAXUD’s Strategic Plan 2020-202448. The latter specifies that the 
following specific objectives are related to the Fiscalis programme: 

a)  Design tax policy actions to build the first carbon neutral continent by 2050 (1.1). The 
Strategic  Plan  announced,  inter  alia,  the  Commission’s  intention  to  revise  the  Energy  Tax 
Directive.  

b)  Develop tax policy actions for a stronger, fairer and more efficient single market (3.1). 
The Strategic Plan highlighted a new focus on taxation policies supporting economic growth, 
and announced measures to simplify the legal framework and amend specific provisions of 
the VAT and excise duties rules, to reduce administrative burdens, and to make full use of 
digital solutions, including data analytics and modernising VAT reporting obligations.  

c)  Implement tax policy actions that contribute to more fairness and social justice (3.2). 
The  Strategic  Plan  announces  DG  TAXUD’s  intention  of  strengthening  administrative 
cooperation  between  tax  authorities  and  with  other  authorities  to  combat  VAT  fraud,  to 
continue to address fiscal risks inherent in excise goods, and to tackle the fraud opportunities 
offered by the exponential increase in e-commerce.  

These  objectives  were  pursued  via  a  variety  of  regulatory  and  political  initiatives.  These 
initiatives benefit from support from the Fiscalis programme. In some cases, the initiatives will rely 
heavily  on  such  support  to  develop  or  update  the  required  IT  systems,  and/or  to  facilitate 
collaboration,  information  exchange  and  capacity  building  between  national  tax  authorities  of 

47  European  Commission  (2020):  An  Action  Plan  for  Fair  and  Simple  Taxation  Supporting  the  Recovery  Strategy. 
COM/2020/312 final. Available at: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52020DC0312. 
48  European  Commission  (2020).  Strategic  Plan  2020-2024  DG  Taxation  and  Customs  Union.  Available  at: 

https://commission.europa.eu/document/download/9c410140-3466-4823-984d-
e97a3743a61c_en?filename=taxud_sp_2020_2024_en.pdf. 

45 

 
 
 
 
 
Member  States  and  the  Commission49.  As  such,  it  is  clear  that  the  objectives  of  the  Fiscalis 
programme  and  the  priorities  of  EU  taxation  policies  have  been  and  continue  to  be  closely 
aligned. The Fiscalis programme 2024 APR notes that the programme continues to contribute to the 
political guidelines set out by the President, in particular to the new plan for Europe’s sustainable 
prosperity and competitiveness, in which taxation is expected to play an instrumental role. 

There  was  no  negative  feedback  from  the  stakeholders  consulted  on  the  extent  to  which  the 
programme  responds  to  EU  policy  needs  and  priorities  in  the  area  of  taxation.  Furthermore,  no 
shortcomings or areas of misalignment between the two were mentioned. It was widely noted that the 
programme objectives and design are broad and flexible enough to address any existing or emerging 
needs and priorities in the area of taxation policy (including combating  tax fraud and tax evasion, 
dealing appropriately with e-commerce and the digitalising tax authorities).  

The ‘core’ taxation policy priorities are addressed extensively in the current iteration of the Fiscalis 
programme. A large number of EESs are being developed, upgraded and/or maintained and there are 
collaborative and competency-building actions on a wide variety of relevant topics. These include a 
project group on Estimation of tax gaps on PIT/SSC, CIT, MTIC fraud and VAT e-commerce fraud, 
a  project  group  on  Multilateral  controls  in  the  field  of  e-commerce,  and  the  CESOP  expert  team 
(which supported the development of a digital system in the area of detecting suspicious cases of 
VAT fraud), to provide just a few examples. 

In principle, the programme is also able to support taxation policy-related activities that address the 
objectives of key ‘adjacent’ policy areas (e.g. environment and climate policy or EU enlargement). 
However,  under  the  current  iteration  of  the  programme,  to  date  (2021-2024)  there  have  been  no 
actions  that  specifically  relate  to  the  green  transition  (e.g.  on  energy  taxation,  or  in  relation  to 
restructuring the Community EU framework for the taxation of energy products and electricity)50. 
Due to this, the 2023 and 2024 APRs note that the programme could still better assist Member States 
in  implementing  tax  reforms  that  support  the  green  transition  and  protect  the  environment. 
Nonetheless,  this  was  not  raised  as  a  significant  gap  or  shortcoming  by  any  of  the  national  tax 
authorities that were consulted for this study. 

In relation to EU enlargement, the Fiscalis programme can provide support to participating candidate 
and potential candidate countries by providing access to collaborative activities as well as to EU-level 
capacity-building  activities.  This  helps  enlargement  countries  with  both  harmonising  and 
implementing the acquis. However, the 2023 APR also stated that there had been ‘a reluctance from 
EU  Member  States  to  invite  enlargement  candidate  countries  to  programme  activities  and  share 
experiences with them’. To address this shortcoming, a dedicated event was organised to facilitate 
cooperation and fully integrate candidate countries into the programme activities. 

Only two candidate countries responded to the survey. They confirmed that the programme is seen 
as an important vehicle to prepare for the application of the EU acquis and the relevant IT systems in 

49 For example, in 2023, a directive amending EU rules on administrative cooperation in the area of taxation was adopted. 
In 2024, the Council adopted the ‘FASTER’ proposal, aimed at making withholding tax procedures in the EU more 
efficient and secure for investors, financial intermediaries and tax authorities, and requiring the implementation of 
numerous digital solutions; the  Commission also proposed a  new  electronic VAT exemption certificate. In March 
2025, the VAT in the Digital Age package was adopted. 

50 Council Directive 2003/96/EC of 27 October 2003. 

46 

 
 
 
the area of taxation. They provided examples of how they had taken advantage of the opportunities it 
provides (e.g. a working visit by officials of one candidate country to another). However, one of them 
reported that they perceived a  ‘difference of opportunities’ between EU  Member States and other 
participating  countries  (regarding  aspects  such  as  budgeting  or  invitations  to  expert  teams)  and 
advocated for the latter to be more involved in programme activities. This difference stems mainly 
from the fact that some candidate countries needed time to become operational under the programme 
(joining in 2022-2023) and set tax policy priorities to work in cooperation with EU Member States.  

➢  Fitness for purpose of the programme’s support for the common components of the EESs, 

collaborative activities, training and other actions 

The  final  evaluation  of  the  2020  Fiscalis  programme  concluded,  inter  alia,  that  the  underlying 
challenges and needs that the programme aimed to address were still present; that the relevance of 
the EESs in the daily operations of both tax authorities and economic operators was high and growing; 
and that collaborative actions were also highly relevant. This interim evaluation sought to explore 
whether  those  conclusions  were  still  valid  for  the  new  iteration  of  the  programme  in  the  current 
context.  Questions  on  the  extent  to  which  different  activities  correspond  to  the  needs  of  EU  tax 
administrations were included in the survey. The responses are shown below. They suggest that all 
three types of activities are well aligned with needs, especially the collaborative activities. 

Specifically,  regarding  the  IT  systems  (i.e.  the  common  components  of  the  EESs),  86%  of 
respondents agreed (almost half of them ‘fully’) that these correspond to their needs. The remaining 
14% responded neutrally; none disagreed. This confirms that, overall, the programme’s support 
for the common components of the EESs is fit for purpose. However, the fact that the responses 
are less ‘enthusiastic’ than for the collaborative actions suggests that there may be scope for some 
improvements in the way these components are delivered, or that awareness of the programme’s role 
in the EESs is still limited. 

Consultations revealed that the most frequent complaints related to the speed and/or agility of 
the processes for updating systems. This can mean that several versions of some IT systems co-
exist and are used for different applications (e.g. CCN and CCN2), causing confusion among users 
as well as an additional burden on the tax administrations that have to maintain channels to connect 
to both versions. Other points made by individual respondents included insufficient communication 
and transparency regarding which systems should be funded and included in MASP-T; a need to 
allocate more resources to maintaining and updating  the systems; and a desire for users to  be 
consulted more frequently, including before any change or update is made. 

As can be seen in Table 16 below, according to  the national  tax authorities  that responded to  the 
survey,  the  collaborative  actions  correspond  very  closely  to  their  needs.  Nearly  all  respondents 
agreed  with  this  statement,  and  over  70%  agreed  ‘fully’.  Some  respondents  explained  that 
collaborative  actions  have  a  positive  impact  on  tax  administrations  and  that,  without  them,  there 
would be a higher risk of misalignment with EU legislation and less tax harmonisation across the EU. 
A couple of respondents also emphasised that Member States have the flexibility to start or participate 
in collaborative actions that best suit their needs as regards compliance with European requirements, 

47 

 
 
 
and  that  the  programme  is  flexible  about  allowing  participating  countries  to  initiate  collaboration 
activities that meet their needs.  

The survey conducted annually among participants in  programme activities asks respondents about 
their level of satisfaction with the activities in question, and about the reasons for this. In the 2023 
survey, 75% of relevant respondents (who had participated in collaborative activities and reported 
they were satisfied or very satisfied with the quality of those activities) selected as one of the reasons 
for their satisfaction the fact that the collaborative activity in question was relevant to their work. 

As regards the human competency-building /  training actions, again,  a clear majority (86%) of 
respondents agreed (a little over half of them ‘fully’) that these correspond to the needs of EU tax 
administrations (with the remainder responding neutrally). This confirms that such actions are also 
fit for purpose, but arguably not quite to the same extent as the collaborative actions referred to above. 
Competency-building actions that were highlighted as especially well aligned with needs included 
the e-learning courses (described by one respondent as ‘excellent’ in terms of completeness and depth, 
interactivity,  methods  of  tracking  the  progress  of  participants  and  use  of  modern  educational 
technologies), the CLEP training courses and workshops for newcomers, and CLEP training courses 
on TNA and CESOP.  On the other hand, some respondents  acknowledged  that they do not  make 
extensive  use  of  the  training  offer,  citing  reasons  such  as  the  existence  of  high-quality  national 
training, language barriers and the fact that some material is not updated frequently enough.  

The case study on the LMS provides further evidence of the relevance of this  system, which was 
launched in 2021 as a single repository for the training and capacity-building activities carried out 
under  the  Fiscalis  programme  (and  Customs  programme).  It  was  created  primarily  to  address  the 
difficulty faced by tax administration staff in locating and accessing training materials. Its centralised, 
searchable platform solved the problem of scattered resources and improved awareness and uptake 
of EU training, particularly for training coordinators who integrate courses into national curricula. 
While the LMS also offers hosting and LTI integration, this is less relevant for larger tax authorities 
with  existing  national  training  platforms  (though  integrating  LTI  functionalities  would  help  the 
Commission track and understand engagement with the courses). Smaller Member States, however, 
may find value in the EU LMS due to cost savings or better functionality. The platform could also 
potentially  host  nationally  developed  training,  benefiting  administrations  with  limited  training 
capacity. Finally, the LMS serves as a central access point for CLEP training, thus making it more 
visible.  

48 

 
 
 
 
 
 
 
 
 
 
5.  WHAT ARE THE CONCLUSIONS AND LESSONS LEARNED? 

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

While the findings are in line with previous evaluations, the emphasis is on the findings derived 
from the specialised  methodology  applied to this  appraisal exercise.  This  focused on in-depth 
case studies of four of the 30 IT systems (i.e. TNA,  DAC6,  VIES-on-the-web and EMCS), each 
of which compared observable experiences and results with a hypothetical ‘counterfactual’ scenario 
of what would have been expected without EU support. The evaluation also included a case study on 
the LMS (a platform introduced in the current iteration of the programme for disseminating e-learning 
courses and other training material produced for the programme) and a programme assessment that 
used desk research, a survey and interviews to assess other aspects of the programme horizontally.  

5.1. Main achievements and strengths of the Fiscalis programme 

As with previous iterations, the 2021-2027 Fiscalis programme can be considered very successful 
at this stage of the funding period. It has continued to adapt to the needs of stakeholders while being 
delivered largely as planned, implementing EU policy and generating real benefits and savings. The 
programme’s  main  achievements  and  strengths  can  be  summarised  in  terms  of  the  four  key 
conclusions listed below. Each one is supported by specific examples from the case studies, which 
accounted for a large part of the data and evidence collected for the evaluation. 

The Fiscalis programme continued to be sufficiently adaptable to remain in line with 
stakeholders’ needs and the wider policy environment 

The programme’s design ensures that both its objectives and the actions selected are driven by the 
policies it exists to support. The programme is first and foremost  aligned with EU tax policy, but 
since  this  is  closely  coordinated  with  wider  policies  and  initiatives  (e.g.  the  green  transition,  EU 
enlargement,  recovery  from  the  pandemic  and  structural  reforms),  the  programme  is  also  broadly 
consistent with other EU policies. Examples of complementarity were found in particular with the 
Customs  programme,  which  is  jointly  managed  by  DG  TAXUD,  as  well  as  the  RRF,  the  closely 
related  TSI  (both  managed  by  SG  REFORM)  and  the  cross-cutting  European  Green  Deal.  The 
evidence collected as part of the evaluation also shows that this alignment is not only conceptual but 
rooted in the wide variety of actions that launched to address specific needs, and in the fitness for 
purpose of the programme’s main components: EESs, collaborative actions and capacity building.  

The Fiscalis programme continues to be successful in implementing its activities and 
delivering on its objectives 

The  design  of  the  Fiscalis  programme  is  needs-based  and  flexible,  with  practical  responsibilities 
allocated according to operational needs. This has allowed the programme to successfully deliver a 
very wide range of activities, from complex IT projects, to a large number of structured and ad hoc 

49 

 
 
 
 
 
collaborative actions, to the development and roll-out of common training material. Achievements 
and  impacts  vary  depending  on  the  nature  and  scale  of  specific  funded  actions.  However,  from  a 
delivery perspective, the programme has met or exceeded initial expectations/targets in all areas, and 
stakeholder perceptions of the programme and its activities are overwhelmingly positive. With regard 
to  the  four  systems  examined  in  the  case  studies,  successful  implementation  has  allowed  tax 
authorities and (where relevant) economic operators to interact in a secure and reliable manner. The 
LMS has also been launched and is operating to a high standard. 

The Fiscalis programme actions mutually reinforce each other and contribute significantly 
to achieving the programme objectives 

All three of the programme’s main action ‘types’ were found to be making significant contributions 
to  the  specific  objectives  of  coherent  tax  policy  and  implementation  of  EU  tax  law;  fostering  of 
operational  cooperation  among  tax  authorities;  and  improved  administrative  capacity  of  tax 
authorities.  This  was  demonstrated  by  the  general  feedback  from  national  administrations,  by  the 
programme monitoring data, and by the findings of the case studies on specific IT systems and the 
LMS. These achievements in turn contributed towards the programme’s general objectives (though 
there are many other factors at play). The evaluation showed that the programme’s impact depended 
not only on the quality and outputs of individual actions, but on the ways they work together and feed 
off  each  other  to  produce  the  desired  outcomes.  As  a  result,  although  simply  considering  the 
programme budget would suggest that most of its added value comes from the IT systems, in fact the 
added value is generated by the combined effects of all types of actions. This is particularly true of 
the  role  played  by  collaborative  actions  in  developing  and  ensuring  the  proper  use  of  funded  IT 
systems.  Such  actions  include,  in  some  cases,  expert  teams,  which  involve  particularly  extensive 
cooperation between participating officials to achieve a common goal.  

The Fiscalis programme continues to generate benefits that far outweigh the costs 

Since the benefits and costs of the programme are highly specific to the action in question, this aspect 
was examined mainly based on the in-depth case studies. In different ways and depending on their 
functions and of tax policy area, the four IT systems examined were found to generate significant 
tangible benefits and cost savings for tax authorities, for the European Commission and – where 
relevant, such as when they use IT systems for compliance purposes – for economic operators. These 
included  efficiency  gains  from  digitalising/automating  tasks  that  were  previously  analogue, 
increased productivity from being able to share more and better information seamlessly, reduced 
waiting times due to the instantaneous availability of information, and direct and indirect effects on 
reducing fraud. The counterfactual analyses generally showed that pooling resources to develop the 
systems at EU level led to systems that were better at fulfilling their functions. They were also more 
cost-effective  than  those  that  could  have  been  achieved  by  the  Member  States  on  their  own.  As 
mentioned  above,  the  collaborative  actions  and  capacity-building  activities  contributed  in  part  by 
helping  to  create  the  environment  needed  for  the  IT  systems  to  function  and  be  used  as 
envisaged, as well as by ensuring a common understanding and implementation of EU tax legislation. 

50 

 
 
 
 
Their relatively low cost was seen as a small price to pay given the leverage generated in terms of 
increasing the effectiveness of the IT systems and giving tax authorities the means to work together.  

5.2. Lessons learned and areas for improvement  

As detailed above, Fiscalis is a highly relevant programme that has generated significant value over 
the years, based on its sound overall design and its ability to adapt and improve incrementally. In that 
spirit, while the evaluation has not found that major changes are needed, this section outlines areas 
and aspects that could be improved, along with potential solutions that could be considered for the 
remainder of the funding period and beyond. 

The Fiscalis programme successfully supports the overall EU tax policy. However, the 
multifaceted policy and political context within which it operates is not always conducive to 
the most effective or efficient course of action 

As commented, the evaluation shows how the programme contributes effectively to supporting EU 
tax  policy  and  ensures  that  the  activities  pursued  under  the  programme  correspond  to  real  needs. 
However, the surrounding context is complex and sometimes not conducive to the course of action 
that would be the most effective or efficient. This is felt most strongly with the IT systems, for which 
the advantages of centralised solutions from an operational and cost-effectiveness perspective 
need  to  be  balanced  with  issues  such  as  existing  legacy  infrastructure  and  national-level 
priorities. In the field of training, a similar situation was observed for the LMS, which is a high-
quality platform that  has not yet realised its full potential (because most Member States still run e-
learning courses from their own LMSs rather than the EU one).  

External  factors  will  always  affect  the  programme’s  room  for  manoeuvre  and  cannot  be  simply 
discounted. When it comes to deciding on which IT solutions to pursue, it has always been difficult 
to assess costs and benefits robustly. This hampers efforts to assess the pros and cons of different 
options. Against this backdrop, the approach pursued in analysing IT case studies did lead to more 
concrete evidence than was previously available of the costs and benefits of several systems. They 
were compared in each case to a plausible alternative. A similar approach could be used in the future, 
either to inform potential changes to existing systems, or to consider the options for new systems. 
Such assessments are time-consuming, and in some cases the option with the best cost-benefit ratio 
may not be feasible for any number of reasons. However, such an approach would still more than pay 
for itself if it led to more informed decision-making for large-scale IT projects.  

The Fiscalis programme is fully coherent with a range of other Commission initiatives in 
terms of alignment of objectives and complementarity of activities and outputs. Concrete 
links with other initiatives continue to be limited 

The evaluation found the Fiscalis programme to be fully coherent with a range of other Commission 
initiatives  in  terms  of  alignment  of  objectives  and  complementarity  of  activities  and  outputs. 
However, this was not the case for others, namely the Hercule component of the UAFP (managed by 
OLAF), for which a recommendation in the previous evaluation proposed introducing a mechanism 

51 

 
 
 
 
 
for coordinating with the Fiscalis programme, the single market programme and the IPA/TAIEX (DG 
NEAR).  

While the initiatives examined showed little risk of overlap with the Fiscalis programme and scope 
for mutual reinforcement even in the absence  of practical  coordination, there may be missed 
opportunities for identifying and exploiting synergies. The evaluation’s focus on IT systems meant 
that these opportunities were not explored in detail. For this reason, it was also unclear why closer 
collaboration with Hercule had not occurred, making it hard to understand whether and to what extent 
this was considered a problem by programme stakeholders. The starting point for addressing the issue 
is thus to decide whether it is in fact a problem, or whether the present situation of ‘passive coherence’ 
with  certain  other  initiatives  is  sufficient.  If  it  is  a  problem,  then  action  towards  establishing 
coordination mechanisms should be pursued. 

The Fiscalis programme effectively combines different types of activities for pursuing 
the desired objectives. Overcoming some of the persisting shortcomings in 
communication, awareness and visibility could further boost the overall success of the 
programme in the future 

The different types of activities funded by the Fiscalis programme are closely linked and, as argued 
above, work together to achieve the desired aims. However, while it is common knowledge that the 
programme’s  IT  systems  are  supported  by  EU  funding,  some  people  are  still  unaware  that  these 
activities form part of the Fiscalis programme. This limits information and data sharing among 
stakeholders  working  on  tax  issues  from  different  perspectives,  and  may  lead  to  missed 
opportunities, for example if IT staff do not know how to seek out support via collaborative actions. 
It  also  leads  to  a  narrow  perception  of  the  programme’s  added  value,  meaning  that  its  role  in 
implementing  EU  policy  is  not  fully  grasped.  The  APRs  and  other  material  produced  on  the 
programme cover both IT aspects and collaborative and capacity-building actions, but these do not 
seem widely read among national administrations.  

In  the  short  term,  awareness  of  the  role  of  the  IT  systems  in  the  programme  could  be  addressed 
through more consistent branding. This would not require significant resources, but rather would 
entail relatively simple efforts such as mentioning in the literature and interfaces of the systems that 
they are funded by the Fiscalis programme and, where relevant, mentioning the link with other funded 
actions. Similarly, NFCs could be asked to make a renewed effort to promote the programme brand 
among users of the IT systems and other national officials, and the Commission could provide support 
by offering guidance and other basic material as needed, emphasising the complementary role of 
different types of actions. The e-learning courses on certain systems could also be used to promote 
the fact that the systems form an integral part of the Fiscalis programme. Over time, this would create 
a  stronger  association  between  the  different  strands  of  funded  activities  and  increase  the 
visibility of the programme.  

The programme’s revised grant management system has proven to be effective and to 
function well despite the persisting differences in the level of experience and administrative 
capacity. This may call for some adjusting in the future 

52 

 
 
 
 
 
 
 
 
 
 
The current programming period has seen a new approach to administering the collaborative actions, 
which  is  the  result  of  the  compulsory  new  approach  for  grants  across  all  Commission 
programmes (including but not limited to the Fiscalis programme). This approach has been applied 
since 2021 and involves electronically managing grants (with a new IT system, eGrants) and using a 
new model grant agreement. This requires beneficiaries to be organised within a consortium, with the 
grant coordinator becoming the single point of contact with the Commission for payments/recoveries. 
Compared to the previous approach, whereby the Commission disbursed funding directly to each of 
the  beneficiaries,  this  represents  a  big  change.  The  Member  States  responsible  for  the  main 
collaborative  action  grant,  and  the  separate  grants  for  individual  expert  teams,  now  have 
considerably more administrative responsibility than in the past. Overall, the system has worked 
well, but levels of experience and capacity differ, which has led to some teething problems.  

To  supplement  the  material  and  guidance  on  grant  management  already  made  available  by  the 
Commission, national administrations could be encouraged to identify and share best practices 
among themselves. A forum  for this  could  be found within an existing  collaborative  action, or  a 
dedicated grant management collaborative action could be set up. This would ensure that successful 
strategies  are  widely  applied  and  help  grants  to  run  more  smoothly  in  the  future.  It  would 
prevent Member States being discouraged from engaging with the programme due to administrative 
constraints.  

The new MEF for the Fiscalis programme is more manageable and purposeful than its 
predecessor. However, there is scope to further simplify and streamline the overall process 
of monitoring 

Compared  to  its  predecessor,  the  new  MEF,  introduced  for  the  current  programming  period,  has 
reduced the number of indicators and simplified data collection and reporting structures, with a view 
to establishing a more manageable and purposeful framework. The new MEF is clearly a step in the 
right  direction,  but  challenges  persist,  including  some  that  were  also  experienced  with  the 
previous  MEF,  such  as  an  excessive  number  of  indicators,  burdensome  processes  for  national 
authorities and the Commission, and sometimes the usefulness of the reports and analysis produced. 

A potential starting point for any changes could be to recognise that the diversity of actions and their 
desired outputs and outcomes limits the amount of insight that can be gleaned from the most readily 
quantifiable metrics. This should serve as a natural limit to the ambitiousness of the programme’s 
MEF. Ideas for potential improvements include (1) minimising the amount of primary data to be 
collected, which would help address  ‘consultation fatigue’ among national coordinators and other 
stakeholders; (2) further exploiting existing data to establish more informative indicators; and 
(3)  reducing  the  number  of  indicators,  particularly  at  an  output  level  where  there  is  often  low 
correlation with programme performance and which is difficult to compare between actions. 

The new LMS supporting the programme is cost-effective. Incremental improvements could 
enhance further its effectiveness in serving training needs in the field of taxation 

53 

 
 
 
 
 
 
 
The evaluation assessed that, as a whole, the LMS platform is of high quality and adds significant 
value at reasonable cost. While the findings were broadly positive, it was also noted that there are 
some areas for incremental improvement, which could be addressed in the short- to medium-term 
to improve the effectiveness of the LMS.  

The findings suggest that the design and functionality of the LMS could be improved in terms of 
the search function, more personalisation for logged-in users and introducing more language versions 
(since the LMS site is currently only available in English)51. Integrating relevant training material 
from  national  administrations  and  other  organisations  could  also  increase  the  LMS  offering 
while simultaneously making such material available to a wider audience. The limited uptake of the 
LTI functionality has been a problem because it is needed to realise the full potential of the LMS, 
particularly  when  it  comes  to  tracking  the  engagement  of  users.  Stakeholders  attributed  their 
reluctance to use the functionality to compatibility and security issues, but in fact the LMS software 
addresses  both  aspects.  This  suggests  that  the  bottleneck  is  more  about  tax  administrations 
needing  information  and  reassurance.  Concentrated  communication  efforts  could  also  boost 
usage  of  the  LMS  and  enhance  its  role  as  a  centre  of  knowledge.  Finally,  some  stakeholders 
expressed confusion as to why CLEP events are organised on the LMS, while other capacity-building 
activities follow a different procedure. Action should therefore be taken either to (1) limit the LMS 
to  being  a  platform  for  e-learning  material  or  (2)  to  make  the  LMS  the  location  for  all  capacity-
building actions funded by the programme.  

51 It should be noted however that many e-learning courses on LMS have been translated to several EU languages, at the 

request of Member States (approx. 1 100 localisations are available in LMS). 

54 

 
 
 
ANNEX I:  PROCEDURAL INFORMATION 

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

The final (PLAN/2024/911) evaluation is a non-major initiative organised in accordance with Article 
15(2) of Regulation (EU) No 2021/847 of 20 May 2021 establishing an action programme 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  the  ‘Study  supporting  the  interim  evaluation  of  the 
Fiscalis 2021-2027 programme’, conducted by an external contractor, Economisti Associati, during 
the  period  June  2024-June  2025.  An  inter-service  steering  group  (ISG)  supported  the  study, 
comprising the following Commission services, which had expressed their wish to participate in the 
group.  

Table 4. Commission services that formed the final study’s ISG 

Meetings and written procedure  
DG AGRI - Agriculture and Rural Development 
DG BUDG - Budget  
DG DIGIT – Digital Services 
DG ECFIN - Economic and Financial Affairs  
DG ENEST - Enlargement and Eastern Neighbourhood 
DG ENV - Environment  
DG GROW - Internal Market, Industry, Entrepreneurship and SMEs 
DG HOME - Migration and Home Affairs  
DG SG - Secretariat-General  
DG REFORM - Structural Reform Support  
Legal Service  
OLAF - European Anti-Fraud Office 

The ISG for the evaluation met five times, on 7 March and 3 September 2024 and on 14 January, 20 
May and 17 June 2025. The last meeting was to validate the ‘Study supporting the interim evaluation 
of the Fiscalis 2021-2027 programme’. During it, the external consultants presented their findings, 
conclusions and recommendations. These were further discussed with the group, and their validity 
and credibility were confirmed.  

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

55 

 
 
 
 
 
 
This evaluation SWD is based on work carried out by external consultants. The material informing 
this evaluation consisted of (1) programming documentation including the MEF; (2) previous studies, 
reports and evaluations; and (3) interviews and targeted surveys, as detailed in Table 5, which also 
describes the intended purpose of use.  

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

Table 5. Sources of information used to evaluate the Fiscalis programme 

Source 
1. Programming documentation  
1.1 Programme  
Regulation (EU) No 2021/847  

1.2 Annual work programmes (AWPs)  
The  Fiscalis  AWPs  are  annexed  to 
each yearly financing decision  

1.3 MEF 

2. Studies, reports and evaluations  
2.1 APRs  
Published yearly, available for 2023, 
2022, 2021 and 2020.  

Purpose 

-  Underlying rationale, history and context  
-  Main features of the programme  
-  Key stakeholders and beneficiaries 
-  Specific and operational objectives  
-  Headline budget figures  
-  Overview of activities and priorities 
-  Structuring and selection of case studies  
-  Priorities in terms of resource allocation  
-  Continuing  relevance  and  policy  issues  of  interest 

for the programme 

-  Expected results and annually updated goals  
-  Evaluation  design,  mapping  MEF  indicators  to 

evaluation questions 

-  Limits of MEF indicators 
-  Purpose and design of different indicators  
-  Practicalities  of  MEF  data  collection  and  their 

consequences 

-  Intervention logic  
-  Programme 
-  Performance/effectiveness in terms of outputs and 

results  

-  Insight into how the MEF is used and reported  
-  Structuring  and  topicality  of  the  evaluation  case 

studies  
-  Perceived 

strengths  and  areas 

further 
development – early warnings and learning within 
the programme  

for 

2.2  Evaluations,  impact  assessments 
and reports  
Final evaluation of Fiscalis 2020 
Action 
evaluation of Fiscalis 2020 

follow-up 

plan: 

final 

-  Previous 

findings, 

conclusions 

and 

recommendations 
to 

-  Background 
programme  

recent  developments 

in 

the 

-  Ideas for other sources of data 

56 

 
 
 
 
3. Interviews and targeted surveys 
3.1 Interviews with representatives of 
national 
the 
Commission  and  relevant  economic 
operators 

authorities, 

tax 

3.2 Targeted surveys 
-  For NFCs 
-  User survey as part of the VoW 

case study 

-  User survey as part of the LMS 

case study 

4.  Use of external expertise  

-  Collect further insight into the perspective of policy 
officers,  national  tax  authorities  and  EES  system 
users 

-  Collect insights from the contractor responsible for 

developing and operating the LMS 

The  Commission  carried  out  the  evaluation  studies  using  external  consultants  procured  through  a 
framework  contract.  The  ‘Study  supporting  the  interim  evaluation  of  the  Fiscalis  2021-2027 
programme’, which is the main study informing this report was conducted by a consortium led by 
Economisti Associati (now Intellera)52. This was signed on 17 June 2024 for a period not exceeding 
10 months. A non-cost extension of the contract until 30 June 2025 was granted at a later date. 

52 Framework contract TAXUD/2024/CC/171 - Lot 1. 

57 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
ANNEX II. METHODOLOGY AND ANALYTICAL MODELS USED 

1.  Approach 

The interim evaluation of the Fiscalis programme mainly builds on the findings of an external study 
conducted by a contractor during the period June 2024 – June 2025. The appraisal of the programme 
over the period 2021-2024 relied on an overall approach that consisted of assessing the relevance, 
effectiveness, efficiency, coherence and EU added value of the Fiscalis programme. To ensure that 
the  assessment  was  robust,  the  structured  approach  depended  on  an  elaborated  intervention  logic, 
operationalised evaluation matrix and a mix of data collection and analytical methods. The overall 
approach included the following three main tasks: 

structuring and scoping, 

- 
-  data collection, 
-  analysis and lesson learned. 

In line with the Commission’s Better Regulation Guidelines53, the evaluation criteria of relevance, 
effectiveness, efficiency, coherence and EU added value were covered. They were addressed through 
15 key evaluation questions: 

1. What are the quantitative and qualitative effects of the programme? 

2.  How  and  to  what  extent  have  the  IT  systems  for  taxation  funded  by  the  programme  contributed  to 
achieving of the general and specific programme objectives? 

3. How and to what extent did the general collaborative activities, expert teams, the human competency-
building activities, and any other relevant activities contribute to achieving the programme’s objectives? 

4. To what extent is the programme effective in communicating on and in disseminating its opportunities 
as well as achievements? 

5. To what extent is the MEF fit for purpose and suitable for providing information on progress towards 
achieving the objectives of the programme? How can it be improved and simplified? 

6.  What  are  the  costs  and  benefits  of  the  EESs  financed  by  the  Fiscalis  programme  for  different 
stakeholders,  including  the  Commission  services?  To  what  extent  is  the  programme’s  funding  of  the 
common components of the EESs cost-effective?  

7.  To  what  extent  are  the  other  (non-EES)  activities  financed  by  the  programme  cost-effective?  In 
particular,  how  efficient  are  the  training  activities  (including  the  use  of  the  learning  management 
system/platform, the e-learning and relayed activities and the common learning events)?  

8. Overall, how efficient is the governance of the programme during the period considered?  

9. Have the objectives of the programme remained in line with single market needs, and with EU policy 
needs and priorities?  

10.  Is  the  programme’s  support  for the  common  components  of the  EESs fit  for  purpose?  If  not,  what 
adjustments can be made, both during the current programming cycle and post-2027? 

53 Better Regulation Guidelines, Commission staff working document SWD (2021) 305 final. 

58 

 
 
 
11. Is the programme’s support for collaborative activities, training, and other actions fit for purpose? If 
not, what adjustments can be made under the current programming cycle (2021-2027)? 

12.  To  what  extent  is  the  programme  coherent  with  other  EU  initiatives/programmes  with  similar 
objectives? 

13. To what extent are the actions funded by the programme internally consistent? 

14. What is the EU added value of the different types of activities funded under the Fiscalis programme? 

15. Overall, what is the EU added value of the Fiscalis programme? 

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

The approach to this exercise was informed by five main considerations. Firstly, the evolution of the 
Fiscalis programme since 1998 – and the fact that its various iterations have been subjected to periodic 
evaluations  ever  since  –  allows  targeted  analysis  of  specific  components,  without  necessitating 
another  complete  assessment.  Secondly,  the  significant  investment  in  IT  systems  requires  a 
the  extensive  coverage  of 
comprehensive  understanding  of 
collaborative activities and capacity building in past evaluations and regular monitoring activities 
has led to ‘consultation fatigue’ among stakeholders (meaning that additional consultation should be 
targeted  and  limited  to  what  is  truly  necessary).  Fourthly,  previous  evaluations  encountered 
difficulties in measuring the costs and benefits of complex IT systems due to limited data. Lastly, 
the recently introduced MEF offers more data and insight into the programme than was available 
for previous evaluations.  

their  effectiveness.  Thirdly, 

2.  Overall methodological framework 

The methodological approach was characterised by a heavy reliance on case studies. This allowed 
key issues that are of specific interest to be investigated in depth, while minimising the assessment of 
the overall programme, already covered comprehensively in previous evaluations.  

The diagram below provides a summary overview of the evaluation approach, structured in terms of 
the three main tasks  as listed above. The  chosen data collection methods aimed to  maximise cost 
effectiveness, minimise duplication with existing information, target relevant stakeholders in a way 
that limits their burden and avoids ‘consultation fatigue’, and generate the evidence needed to address 
the evaluation questions, in particular as regards the use, results, costs and benefits of the IT systems. 

59 

 
 
 
Figure 14. Fiscalis programme evaluation approach 

Source: Economisti Associati study 

Structuring and scoping 

The analytical framework initially drawn up was supplemented by desk research reviewing existing 
programme documentation, annual progress reports and policy documents. An evaluation matrix was 
aligned with the Fiscalis programme intervention logic to establish clear indicators, data sources and 
judgement  criteria  for  each  evaluation  question.  The  evaluation  matrix  (Annex  III)  addressed  15 
questions  and  sub-questions,  focusing  on  the  programme’s  effectiveness,  efficiency,  relevance, 
coherence and EU added value. This task also involved developing the methodology, which included 
establishing the sample of four EESs and the LMS for in-depth case studies and the data collection 
strategy, both of which are described in more detail below.  

The most extensive and important feature of the methodology for this evaluation was the case 
studies on four EESs, which were carried out  to  allow an in-depth  assessment  of the aspect  that 
absorbs most of the Fiscalis programme funding (namely the IT systems). Rather than aiming to cover 
a representative sample of the approximately 30 EESs, the case studies sought, for several different 
types of systems54, to go into more depth than has been possible in the past and thereby shed new 
light on the costs and benefits, and the factors promoting and hindering success. Previous evaluations 
found it very difficult to provide quantified estimates of the costs and benefits of the IT systems (and 
of the Fiscalis programme support for them), partly because the point of comparison against which 
such costs and benefits should be assessed is not always clear. This is due, among other things, to the 

54  The sample was chosen with a view to  covering a range of approaches to IT systems (namely centralised vs decentralised), the 
different  types  of  taxation  (direct,  indirect  and  excise)  and  both  long-established  systems  and  systems  that  had  been  recently 
introduced. 

60 

 
 
 
 
 
fact that IT systems typically go hand-in-hand with EU legislation that makes digital data exchange 
mandatory. Therefore one cannot always simply assume that the absence of (the common components 
of)  the  EESs  would  mean  a  return  to  the  previous  situation  of  mostly  paper-based  exchange  of 
information.  To address  this issue, a novelty for this evaluation  was to  compare each system  to  a 
hypothetical ‘counterfactual’ scenario of what may have been expected in the absence of EU funding. 

The only ‘non-IT’ case study – on LMS – served to examine an aspect of the programme that was 
new for the current funding period. The programme assessment, rather than covering all remaining 
actions in detail, was a limited exercise aimed at confirming the validity of previous evaluations and 
gathering new insight into issues of particular interest, most importantly the EU added value of the 
collaborative actions and expert teams. 

Data collection and analysis 

Existing documentation such as policy and programming documents, the Fiscalis programme APRs 
and MEF data were reviewed to provide foundational understanding and context. Key information 
and gaps were systematically mapped to guide further data collection steps. Data for both the case 
studies and the programme assessment were collected via three main methods:  

1.  desk research to review a wide range of relevant sources of secondary data and information; 

2.  interviews  with  representatives  of  national  tax  authorities,  the  Commission  and,  where 
relevant, economic operators and external contractors (in total 84 interviews were carried out, 
in addition to ad hoc interactions with key Commission stakeholders);  

3.  three  separate  targeted  surveys:  a  survey  of  NFCs  in  the  national  tax  authorities  of 
participating countries (27 responses), online user surveys as part of two of the case studies 
(on VoW, 1 248 responses) and the LMS survey (62 responses).  

Overall, the evaluation sought to collect both qualitative and quantitative data, and data on both the 
implementation of the programme and its impact.  

Case studies on EESs 

The selected case studies, VoW and TNA (indirect taxation), EMCS (excise duties) and DAC6 (direct 
taxation), were chosen to ensure diversity in terms of system type, policy significance and age. The 
evaluation  aimed  to  assess  the  effectiveness,  efficiency,  relevance  and  EU  added  value  of  these 
systems while providing detailed cost-benefit analyses. 

To conduct the case studies, a specialised methodology was employed, comprising comprehensive 
desk  research  and  up  to  20  in-depth  stakeholder  interviews  per  case  study  (Annex  V).  These 
interviews included national tax authorities, EU officials, and system users across Member States, 
providing a diverse and rich set of perspectives. The research focused on reviewing technical and 
operational documents, fiscal performance data and existing policy documents. Triangulation of these 
data sources ensured the consistency and validity of the findings. 

The evaluation also involved constructing ‘counterfactual’ scenarios to better assess the impact of the 
systems,  by  comparing  the  actual  costs  and  benefits  they  generate  with  a  hypothetical  alternative 
situation  where  no  Fiscalis  programme  (or  other  EU)  funding  is  available  for  developing  and 

61 

 
 
 
maintaining the systems in question. Two main types of counterfactual situation were considered, 
with the most appropriate one for each case study chosen as a point of comparison:  

•  One  potential  counterfactual  scenario  was  a  hypothetical  continuation  of  the  prevailing 
situation before  the system in question became operational, allowing  a simple  ‘before and 
after’ comparison. However, this counterfactual scenario was not always appropriate as 1) certain 
systems have been in use for over 20 years, making a return to paper-based information exchange 
unlikely, and 2) many systems serve to address specific, legally mandated requirements within 
EU legislation, meaning that a scenario where they simply did not exist would be unrealistic, as 
it would not take into account the obligation for the various parties (including the Member States) 
to comply with the relevant legal requirements to facilitate the electronic exchange of data. 

•  The other counterfactual scenario considered was to assume that Member States would still 
need to meet the relevant legal obligations, but do so without  EU support – in  particular, 
without  the  Fiscalis  programme  funding  for  common  systems,  components  and/or  technical 
specifications. In other words, the Member States would have to find ways to ensure the relevant 
data could be exchanged electronically, without relying on the EU to support interoperability or 
centralised systems for data exchange. 

Non-IT case study 

In addition to the four case studies on EESs, the evaluation included a dedicated case study on the 
LMS. The LMS (officially called the Customs & Tax EU Learning Portal)55, was launched in May 
2021 as a one-stop shop for all training and capacity-building activities carried out under the Fiscalis 
and  Customs  programmes.  The  LMS  portal  grants  access  to  e-learning  courses,  webinars,  nano-
learning modules, and e-books, of which some are restricted to customs and tax officials while others 
are also open to other interested stakeholders (e.g. economic operators and academics). It also acts as 
the  centralised  access  point  to  Common  Event  Learning  Programme  (CLEP)  trainings,  allowing 
national officials to present their applications for participating in online or in-person events.  

This case study did not evaluate the content of the e-learning materials or the CLEP trainings, as that 
had already been thoroughly analysed in previous assessments, and the findings remained applicable. 
Instead, the case study concentrated on the LMS as a platform. It examined how well the platform 
meets the needs and expectations of Member States, identified areas for functional improvement, and 
assessed its complementarity with other national and international initiatives. Additionally, the case 
study has a forward-looking element, aiming to explore potential changes that could enhance its value 
for  Member  States.  To  achieve  this,  it  investigated  possible  new  features  that  might  benefit  the 
Member States and assessed how receptive they were to broadening the LMS’s role to include hosting 
national training modules in addition to European ones.  

The  data  collection  for  this  case  study  included  background  information,  comprising  the  original 
business case for the LMS, tender specifications and contracts for its development and operation, and 
budgetary  data.  It  also  included  the  LMS  platform  itself  and  the  training  catalogue.  Additionally, 
statistical  data  on  courses  downloaded,  courses  completed,  registered  users,  participation  levels 
among  public  officials  and  private  stakeholders,  and  learning  outcomes,  as  well  as  basic  website 

55 https://customs-taxation.learning.europa.eu  

62 

 
 
 
statistics, were collected. Documents on the LMS produced by DG TAXUD and the Training Support 
Group (TSG) were also included, such as the results of a survey of national training coordinators and 
a forward-looking paper by DG TAXUD on the future of the LMS. 

The stakeholder consultation consisted of two main parts. Firstly, eight interviews were conducted 
with DG TAXUD, the contractor responsible for developing and operating the LMS, and tax officials 
taking part in the TSG from five Member States. Secondly, a survey of LMS users was promoted on 
the  LMS  site  itself  as  well  as  by  TSG  members.  The  survey  was  conducted  in  common  with  the 
parallel  case  study  on  the  LMS  for  the  Customs  platform  and  garnered  62  replies.  Of  these,  10 
mentioned an interest in taxation only, and 19 mentioned an interest in both taxation and customs; 
the remaining 33 respondents expressed an interest in customs only and are not referred to in this 
report. Of the respondents interested in tax, 15 were from tax authorities, 10 from customs authorities, 
two represented both tax and customs administrations, and two were from private organisations. 

63 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table 6. Data collection across case studies 

Case study 

Desk research 

Interviews 

Survey 

EES case studies 

The  results  of  the  Public  Consultation  on  the 
Functioning  of  the  administrative  cooperation 
and  fight  against  fraud  in  the  field  of  VAT, 
Taxation,  Business, 
and 
representatives organizations 2017. 

public 

the 

VIES 

on-the-Web 

Data  on  costs  for  development,  support, 
maintenance  and  infrastructure  for  the  years 
2021, 2022,  and  2023;  and data on number of 
messages  exchanged  and  availability  of  the 
VoW central system. 

Short survey launched which collected 
1 248 
responses  across  economic 
operators. 

interview  with 
1 
Commission (DG TAXUD).  

European 

6  interviews  with  Member  States’ 
tax  authorities  (members  of  the 
on 
Standing 
Administrative Cooperation (SCAC) 
and  on  Information  Technology 
(SCIT)). 

Committee 

interviews  with 
(including 

6 
operators 
associations and companies). 

economic 
business 

2015 and 2020 EMCS evaluation studies. 

2 interviews with DG TAXUD. 

N/A 

EMCS 

TNA 

2018 Impact Assessment proposal for a Council 
Directive laying down the general arrangements 
for excise duty (recast). 

Data on traffic through EMCS and information 
on the different programme phases. 

The 2015 ECA Report. 

The  final  evaluation  of  the  Fiscalis  2020 
programme. 

Statistics on the results achieved by TNA.  

Data  on  costs  for  development,  support, 
maintenance  and  infrastructure  for  the  years 
2021, 2022, and 2023. 

information  provided  bilaterally  by 

Any 
interviewees. 

Relevant legislation and policy documents 

Existing assessments and evaluations 

DAC6 

The yearly assessments, i.e. the questionnaires 
compiled annually by each Member State  

DAC6 statistics 

Non-IT case study 

3  interviews  with  Member  States’ 
tax authorities. 

interviews  with 

5 
associations. 

industry 

interviews  with 

6 
operators. 

economic 

5  interviews  with  representatives 
from DG TAXUD. 

N/A 

(ELOs) 

(including 

15  interviews  with  Eurofisc  liaison 
officers 
the 
Eurofisc chair and grant coordinator 
for the TNA expert team; the current 
and  WF2 
and 
coordinators; the Europol, EPPO and 
OLAF 
point  within 
Eurofisc). 

former  WF1 

contact 

13  interviews  with  Member  States 
the 
(including  members 
of 
Administrative  Cooperation 
on 
Direct Taxation – ACTD). 

N/A 

Background  information,  e.g.  LMS  business 
case, contractual information, budgetary data 

The LMS platform itself and training catalogue 

LMS 

Statistical data  

Documents  on  the  LMS  produced  by  DG 
TAXUD and the Training Support Group (TSG) 

8  interviews  with  DG TAXUD,  the 
contractor 
for 
developing  and operating  the  LMS, 
and tax officials from 5 MS. 

responsible 

A survey of LMS users that was 
promoted on the LMS site itself, as 
well as by TSG members. The survey 
was conducted in common with the 
parallel case study on the LMS for the 
Customs platform and collected 29 
relevant replies56. 

Source: own analysis 

56 10 replies mentioned an interest in taxation only and 19 mentioned an interest in both taxation and customs; there were 
also 33 additional respondents expressing an interest in customs only, which are not referred to in this evaluation. 

64 

 
 
 
 
 
 
 
Programme assessment 

The five case studies were complemented by a broader programme assessment which aimed to gather 
evidence on the Fiscalis programme as a whole and validate and to update the findings of the previous 
Fiscalis programme evaluations. The analysis covers all evaluation criteria, with particular attention 
to the EU added value, with the purpose of gathering any evidence indicating what the consequences 
of discontinuing support to certain actions would be.  

Data collection for the programme assessment focused on three elements: the desk review of a variety 
of  documents  and  sources  of  information  (including  the  updated  MEF,  the  Fiscalis  programming 
documents,  previous  evaluations  and  assessments,  as  well  as  other  documentation  monitoring  the 
programme (e.g. annual progress reports – APR)); an online survey of national Fiscalis coordinators; 
and  14  interviews  with  EU  and  national-level  counterparts,  as  well  as  exchanges  with  key  DG 
TAXUD stakeholders.  

Final analysis and lessons learned 

Part  of  the  extensive  analysis  of  both  quantitative  and  qualitative  data  collected  throughout  the 
programme  was  carried  out  by  using  statistical  software  for  survey  responses  and  programme 
indicators to identify trends, correlations, and impact metrics. This included cost-benefit analyses (to 
the extent possible, see discussion of limitations below) derived from the case studies. Qualitative 
data  were  processed  using  coding  techniques  to  reveal  themes  and  patterns  within  interview 
transcripts and survey responses. Triangulating data across multiple sources ensured the reliability 
and consistency of conclusions. 

The  conclusions  drawn  from  this  comprehensive  analysis  addressed  the  five  required  evaluation 
criteria of effectiveness, efficiency, relevance, coherence, and EU added value. These highlighted the 
achievements of the Fiscalis programme while also pinpointing areas for improvement, supported by 
robust  evidence.  A  stakeholder  workshop  was  also  organised  by  the  contractor  carrying  out  the 
external supporting study to validate the preliminary conclusions and incorporate additional feedback 
from representatives of Member State tax authorities, aiding in the refinement and completion of the 
analysis.  

Additionally,  the  analysis  phase  identified  lessons  learned,  best  practices,  and  areas  for  potential 
improvement. These lessons are deemed relevant for enhancing future programming decisions and 
increasing the programme’s overall impact and efficiency.  

3.  Limits to the evidence base and robustness of findings 

Rather than aiming to cover a representative sample of the approximately 30 EESs, the case studies 
sought, for several different types of system57, to go into more depth than has been possible in the 
past,  and  thereby  shed  new  light  on  the  costs  and  benefits,  and  factors  promoting  and  hindering 
success. Previous evaluations found it very difficult to provide quantified estimates of the costs and 

57 The sample was chosen in conjunction with DG TAXUD with a view to covering a range of the types of approaches to 
IT systems (namely centralised vs decentralised), the different types of taxation (direct, indirect and excise), and both 
long-established systems and systems that had been recently introduced. 

65 

 
 
 
 
benefits of the IT systems (and of the Fiscalis programme support for them), partly because the point 
of comparison against which such costs and benefits should be assessed it is not always clear. One 
reason for this is that IT systems typically go hand-in-hand with EU legislation that makes digital 
data exchange mandatory, and so one cannot always simply assume that the absence of (the common 
components  of)  the  EES  would  imply  a  return  to  the  previous  situation  of  mostly  paper-based 
exchange of information. To address this issue, a new feature of this evaluation was to compare each 
system to a hypothetical ‘counterfactual’ scenario – agreed with DG TAXUD – of what may have 
been expected in the absence of EU funding. 

The  only  ‘non-IT’  case  study  –  which  looked  at  the  LMS  –  served  to  examine  an  aspect  of  the 
programme that was new for the current funding period. The programme assessment, rather than 
covering all remaining actions in detail, was a limited exercise aimed at confirming the validity of 
previous evaluations and gathering new insight into issues of particular interest to DG TAXUD, most 
importantly the EU added value of the collaborative actions and expert teams. 

Overall, the methodology proved effective. The counterfactual approach to the case studies on EESs, 
harvested insights of a different nature and scale than had been previously achieved, by pinpointing 
the ways in which EESs – together with related collaborative actions – affect the work of national 
administrations and economic operators and generate EU added value, compared to the most likely 
alternative  scenario.  With  some  minor  exceptions,  it  was  possible  to  identify  and  engage  with 
stakeholders as hoped, ensuring that the case studies were able to build a solid evidence base. The 
LMS case study and programme assessment were also implemented largely as planned and obtained 
the expected input. That said, there are two key limitations that should be pointed out:  

▪  Trade-off  between  depth  and  breadth:  based  on  the  considerations  set  out  above,  the 
evaluation deliberately chose to go into more depth on specific IT systems, which necessarily 
meant  that  other  IT  systems  and  aspects  of  the  programme,  particularly  the  collaborative 
actions, could not be assessed in as much detail as for previous evaluations. For this reason, 
the evidence for certain evaluation questions (particularly those not focused on the EESs) was 
limited. In these cases, key findings and conclusions from previous evaluations were used as 
a starting point, and either confirmed, refuted, or built on, based on the available data and 
information. 

▪  Fragmented IT cost data: the rationale for the approach based on in-depth IT case studies 
was to include a detailed ‘cost-accounting’ exercise on the systems being studied. As part of 
this,  the  study  involved  IT  cost-accounting  experts  on  the  team,  and  developed  a  detailed 
framework for EU-level costs in agreement with DG TAXUD. However a reduced data set 
was available, covering fewer cost categories and a shorter timeframe than initially planned. 
For this reason,  while the  IT  case studies were  able to  generate significant  and  – in  many 
instances,  quantitative  –  insight,  it  was  not  possible  to  conduct  the  full  cost-accounting 
exercise initially planned. 

66 

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

Table 7. Evaluation matrix – Effectiveness 

Evaluation questions 

Judgement criteria 

Indicators 

1.  What  are  the  quantitative  and 
the 

effects 

of 

qualitative 
programme? 

•  Extent  to  which  the  Fiscalis  programme  has 
different 

tangible 

results 

for 

generated 
stakeholders. 

•  Extent  to  which  the  Fiscalis  programme  has 
contributed  to  the  expected  general  and  specific 
impacts. 

•  MEF results (RES) indicators and sub-indicators (in particular, RES 1.1.1, 1.1.2, 2.2.1, 3.2.1, 3.2.2). 

•  Quantified benefits of specific systems and activities obtained via the case studies. 
•  Qualitative evidence from relevant consultation activities, including on benefits generated by the programme. 

•  MEF impact (IMP) indicators and sub-indicators (in particular, IMP 1.1, 1.2, 2.1, 3.1). 

•  Qualitative and quantitative results from the case studies. 
•  Qualitative evidence from relevant consultations. 

•  Qualitative and quantitative results from case studies. 

•  Extent to which external factors have positively or 
negatively  affected  progress  towards  the  general 
and specific objectives of the programme. 

•  Qualitative and quantitative evidence (from relevant documents and consultations) of external factors that have 

acted as a catalyst or obstacle. 

•  Results  of  contribution  analysis,  taking  into  account  Member  States’  resources,  priorities,  capabilities  and 

broader changes in the taxation landscape. 

•  Extent to which the Fiscalis programme has given 
rise to unexpected or unintended impacts, which 
may have hindered or accelerated progress. 

•  Qualitative and quantitative evidence from case studies. 

•  Qualitative and quantitative evidence (from relevant documents and consultations) of impacts stemming from 

the implementation of the Fiscalis programme which were not provided for in the MEF. 

2.  How  and  to  what  extent  have 
the  IT  systems  for  taxation 
funded  by 
the  programme 
contributed  to  the  achievement 
of  the  general  and  specific 
programme objectives? 

▪  Extent  to  which  IT  systems  contributed  to  the 
general objectives of the Fiscalis programme. 

▪  Nature of the Fiscalis programme IT systems’ role 
in the achievement of a full implementation of the 
EESs, including their common and, to the extent 
relevant,  national  components,  for 
the  full 
implementation  and  application  of  EU  taxation 
systems. 

•  In-depth quantitative and qualitative assessment of the benefits (results, contribution to impacts, broken down 

by general objective) of IT systems selected for case studies. 

•  High-level  assessment  of  key  benefits  of  other  IT  systems  (those  not  selected  for  case  studies)  against  the 

Fiscalis programme’s general objectives, based on relevant documentation and stakeholder feedback. 

•  MEF output (OP) indicators and sub-indicators (in particular, OP 1.1.1, 1.1.2, 1.3.1, 1.1.4, 1.2.1, 1.2.2, 1.2.3). 

•  Qualitative evidence on adherence to timelines as per MASP-T, and reasons for delays (if any). 

•  Significance of the common components for the effective functioning of the EES. 

67 

 
 
Evaluation questions 

Judgement criteria 

Indicators 

▪  Extent  to  which  MASP-T  fulfils  its  purpose  of 
‘ensuring  coherence  and  coordination  of  MS’s 
capacity within IT development and by that secure 
that  the  MS  have  the  resources  to  cope  with  the 
tasks’, and whether it could be improved. 

▪  Extent 

to  which 
activities  have  been  used 
programme’s objectives. 

the  Fiscalis  programme’s 
the 

to  achieve 

teams, 

3. How and to what extent did the 
general  collaborative  activities, 
expert 
the  human 
competency-building,  and  any 
other 
activities 
contribute to achievement of the 
programme’s objectives? 

relevant 

▪  Extent 

to  which 

the  general  collaborative 
activities  (other  than  the  expert  teams)  generate 
benefits. 

▪  Extent to which the expert team generate benefits. 

•  Stakeholder  feedback  on  the  role  of  the  Fiscalis  programme  in  facilitating  the  development  of  national 

components to achieve full implementation. 

•  Qualitative evidence from relevant documents and stakeholder feedback on the role of MASP-T as a project 

support and planning tool. 

•  Shortcomings of MASP-T and suggestions for improvement (if any). 

•  Number  and  types  of  general  collaborative  activities,  expert  teams,  human  competency-building,  and 

innovation activities implemented to date (incl.  

•  Outputs and results generated by these activities (incl. relevant MEF sub-indicators under OP 2.1, OP 2.2, RES 

1, RES 2.2, RES 3.2) 

•  Stakeholder feedback on the use, usefulness and results of each of these types of activities. 
•  Stakeholder feedback on potential improvements to make the activities more effective. 

•  Participant  and  stakeholder  feedback  on  the  use,  usefulness  and  results  of  general  collaborative  activities 

(seminars, workshops, project groups, bilateral or multilateral controls, etc.) (esp. OP 2.1.4). 

•  Relevant findings on the effectiveness of general collaborative activities in relevant documentation (including 

annual progress reports). 

•  Levels of tax authority awareness, interest and participation in expert teams (esp. OP 3.1). 

•  Qualitative and quantitative evidence from documentation and stakeholder feedback on: 

o 

o 

o 

extent to which the pooling of resources across MSs via expert teams effectively supports the development 
and implementation of IT systems; 

extent to which the pooling of resources across MSs via expert teams generates other relevant results; 

extent to which expert teams have generated concrete outputs and results to date. 

•  Extent to which outputs and results of expert teams are being used. 

▪  Extent to which the learning management system 
for customs and tax (LMS) benefits the objective 
of  supporting 
tax  authorities  and  correct 
application  of  the  taxation  rules  in  order  to 
enhance the functioning of the single market. 

•  Number and types of training (IT training workshops, e-learning, CLEP) delivered, professionals trained (OP 

2.2.2). 

•  Participant feedback on quality of the training (OP 2.2.3) and contribution to improving performance (RES 

3.2.2), supplemented by detailed input from the dedicated case study. 

•  Contribution of common training to the Fiscalis programme impacts (assessed via a dedicated case study). 

68 

 
Evaluation questions 

Judgement criteria 

Indicators 

4.  To  what  extent 

is 
effective 

the 
in 
programme 
communicating  on  and 
in 
disseminating  its  opportunities 
as well as achievements? 

information 

5.  To  what  extent  is  the  MEF  fit 
for  purpose  and  suitable  for 
providing 
on 
progress  towards  achieving  the 
objectives  of  the  programme? 
How  can  it  be  improved  and 
simplified? 

▪  Extent 

to  which  other  activities  (such  as 
innovation  or  ‘any  other  relevant  actions’  (as 
referred  to  in  the  Fiscalis  Regulation,  Article 
7(2)(e)(iv)) make a significant contribution to the 
general and specific objectives of the programme. 

▪  Extent to which national customs officials whose 
duties  fall  within  the  domain  of  the  Fiscalis 
programme are aware of the programme. 

▪  Extent to which the programme includes specific 
communication  activities  and  initiatives  seeking 
to drive engagement in the programme. 

•  Extent to which the data gathered under the MEF 
the 

track  progress  and  keep 

is  useful 
to 
programme under review. 

•  Quantitative and qualitative assessment of the number and type of ‘any other relevant actions’ included in the 

MAWP and implemented, based on available documentation. 

•  Stakeholder feedback on these actions, especially about their results and usefulness.  

•  Degree of awareness of the programme among national officials (OP 3.1). 
•  Number of national officials trained (OP 2.2.2). 

•  Stakeholder  feedback on  the  effectiveness,  adequacy,  and  sufficiency of  communication  and dissemination 

efforts. 

•  Stakeholder feedback on potential improvements to communication activities. 

•  Degree to which the present evaluation study is able to use MEF data as evidence. 

•  MEF contributors’ feedback on the usefulness of MEF for the implementation of the Fiscalis programme. 
•  MEF contributors’ feedback on data quality, reliability. comprehensiveness, and timeliness. 

•  Extent to which the administrative burden linked 
to  the  MEF  could  be  reduced  and  the  MEF 
simplified. 

•  Stakeholder feedback on the level of complexity of data provision arrangements. 
•  Stakeholder feedback on overlaps and gaps in MEF.  

69 

 
Summary response to evaluation questions on EFFECTIVENESS 

The findings of the evaluation largely confirmed the key conclusions of the final evaluation of the 
Fiscalis  2020  programme,  which  found  that  the  programme  contributed  to  the  improved 
functioning of the EU Single Market by supporting the fight again tax fraud, tax evasion and 
aggressive  tax  planning.  This  emerged  from  the  feedback  collected  from  national  Fiscalis 
coordinators, who highlighted that all three types of activities, i.e. EESs, collaborative actions, and 
human capacity-building activities, have continued to generate positive effects in this respect. 

Table 8. IT systems contribution to the achievement of general objectives – evidence from case studies 

Case study 

Evidence of impact 

VoW 

EMCS 

TNA 

DAC6 

While  the  primary  objective  of  the  system  is  to  minimise  the  administrative  burden  for 
economic operators when complying with this obligation, the system also aims to reduce 
both involuntary mistakes and, ultimately, fraudulent behaviour. The reliability and the very 
extensive and growing use of VoW by businesses shows its vital role in this task, which was 
confirmed by interviews and large-scale survey (about 1 300 respondents) conducted for the 
study. The tax authorities interviewed also agreed that VoW helps reduce VAT fraud and 
further emphasised that the system helps them identify fraudsters. 

The latest innovation introduced  to the EMCS fulfilled its purpose of reducing fraud and 
illicit trade, although precise estimates are generally not available. The system had a pre-
emptive impact, acting as deterrent to fraudulent behaviour, as traders know that it allows 
real-time verification of consignments. In addition, the direct experience of tax authorities 
suggests  that,  particularly  for  duty-paid  B2B  frauds,  the  digitalisation  of  paper-based 
procedures has had a noticeable – although hard to quantify – impact on fraud reduction. 

Since its introduction the system has led to the identification of 12 000 fraudulent traders 
and to the de-registration for VAT of 6 000 suspicious traders. It allowed the uncovering of 
nearly  EUR  34  billion  in  suspicious  transactions  between 2021  and  2023,  and  led  to  the 
prevention of fraud (unquantifiable but likely significant) thanks to the early identification 
of fraudsters and to their reduced amount of time they can operate before being discovered.  

Most  tax  authorities  (23  out  of  27)  have  started  using  the  information  received  for  risk 
assessment and tax audits. However, tangible benefits have  still not been identified from 
DAC6  exchanged.  On  the  one  hand,  the  results  of  preventative  measures  are  typically 
extremely hard to measure. On the other hand, any results from audit (e.g. additional taxes 
assessed or recovered) will take time to materialise, as complex cases take time – often years 
– to conclude, while the cases that end quickly typically involve legitimate taxpayers. 

Source: Economisti Associati study 

More generally, several of the MEF indicators collected by DG TAXUD suggest an improvement 
in the safeguarding of Member States’ tax bases through the reduction of tax fraud and tax evasion. 
Macroeconomic indicators such as the VAT gap have continuously decreased over the years, while 
total tax revenues increased in absolute value, and remained broadly stable as a percentage of GDP. 
These indicators are a positive sign, even if, as also highlighted by the final evaluation of the Fiscalis 
2020  programme,  the  contribution  of  the  programme  within  these  trends  cannot  be  readily 
isolated. 

70 

 
 
 
Table 9. Evaluation matrix – Efficiency 

Evaluation questions  

Judgement criteria 

Indicators 

6. What are the costs and benefits of 
the EESs financed by the Fiscalis 
programme for different 
stakeholders, including the 
Commission services? To what 
extent is the programme’s funding 
of the common components of the 
EESs cost-effective?  

• 

Specific costs of different EES common 
components for taxation financed by the 
programme.  

•  Quantitative data on aspects such as:  

o 

o 

Procurement contracts (e.g. overall value, FTEs);  

In-house resource allocations.  

•  Case studies with detailed cost-benefit analysis (CBA) for specific EES systems.  

•  Qualitative evidence from documentation and stakeholder feedback.  

•  Extent to which the costs are proportional to 

Fiscalis’ programme objectives.  

•  Analysis of activities supported through the Fiscalis programme’s budget in the case studies.  

•  Qualitative  stakeholder  feedback  on  the  efficient  use  of  resources  for  the  achievement  of  programme 

objectives, esp. around external factors that may have caused additional costs (if any).  

•  Extent to which there is scope for 

•  Analysis of activities supported through the Fiscalis programme’s budget in the case studies.  

simplification, cost optimisation, and 
synergies.  

•  Qualitative stakeholder feedback on the presence of inefficiencies, overlaps, duplications.  

•  Extent to which the EESs financed by the 

Fiscalis programme have generated tangible 
benefits and cost savings for tax authorities, 
the European Commission, and economic 
operators.  

•  Extent to which the current contractual 
management of the EES common 
components allow for the identification of 
costs for each individual system.  

•  Extent to which the current accounting and 
cost-reporting approach has benefits and 
drawbacks.  

•  Tangible benefits resulting from the introduction of specific EES components, such as:  

o  Reduced administrative burden for stakeholders due to improved processes;  

o  Reduced frequency of errors or miscommunication due to structured format of information;  

o  Reduced risk from cyber incidents or loss of data;  

o  Economies of scale resulting from the introduction of EES common components;  

o 

Improved cooperation among tax authorities, leading to improved tax collection / reduced fraud 
rates.  

•  Existence  and  availability  of  sufficiently  detailed  information  on  cost  components  in  procurement 

documents and internal budget documents.  

•  Qualitative document review and stakeholder feedback on current management arrangement and reporting 

obligations.  

7. To what extent are the other (non-
EES) activities financed by the 
programme cost-effective? In 

•  Extent to which training activities are 
implemented under the Fiscalis 
programme.  

•  Number and type of training (IT training workshops, e-learning, CLEP) delivered, professionals trained (OP 

2.2.2) compared to costs of training modules and other activities.  

71 

 
 
Evaluation questions  

Judgement criteria 

Indicators 

particular, how efficient are the 
training activities (including the use 
of the learning management 
system/platform, the e-learning and 
relayed activities and the common 
learning events)?  

8. Overall, how efficient is the 

governance of the programme 
during the period considered?  

•  Extent to which training activities and 
complementary services (learning 
management system, e-learning, and 
common learning events) are cost-
effective.  

•  Qualitative stakeholder feedback on cost effectiveness of training activities.  

•  Cost per training participant (based on OP 2.2.2).  

•  Quality of e-learning courses (OP 2.2.3). 

•  Qualitative stakeholder feedback on usefulness and efficiency of training activities.  

•  Extent to which other activities, are 

•  Stakeholder feedback on efficiency of such activities.  

perceived as cost-effective.  

•  Extent to which programme governance is 

•  Qualitative  feedback  on  planning  and  implementation  aspects,  including  the  use  of  MASP-T  (and 

perceived as efficient.  

differences compared to the period prior to the introduction of MASP-T).  

•  Qualitative stakeholder feedback on perceived efficiency of the Fiscalis programme’s governance.  

•  Qualitative feedback on the usefulness of MAWPs.  

72 

 
 
 
 
 
 
 
 
 
Summary response to evaluation questions on EFFICIENCY 

The evaluation  identified multiple benefits  that the four EESs have brought  to  tax authorities and 
economic  operators.  Process  automation  has  led  to  notable  efficiency  gains,  allowing  tax 
administrations both to save and to redirect resources from routine tasks to more productive, 
strategic  roles  like  fraud  detection.  Additionally,  these  systems  have  yielded  several  indirect 
impacts such as fraud deterrence and a reduction in waiting times, which improves commercial 
activity  and  protects  the  EU’s  tax  revenues.  Economic  operators  also  benefit  from  substantial 
savings in resource allocation and VAT verification costs, particularly with VoW and EMCS. 

Despite these successes, there remain areas for improvement. Enhancing the user-friendliness of 
the  systems  and  considering  greater  centralisation  could  deliver  further  efficiencies,  although  any 
changes has to be analysed against the sensitivity of information and political priorities. There are 
several other specific suggestions for simplification for each case study including: expanding TNA 
data sources, using AI to increase efficiency, standardising data across Member States for VoW, and 
addressing DAC6 manual input challenges in third countries. Overall, while the Fiscalis programme 
has  markedly  improved  the  efficiency  of  the  administration  of  and  participation  in  the  EU’s  tax 
regime, ongoing refinements and improvements could further optimise its impact. 

It needs to be acknowledged that since this evaluation focused primarily on assessing (via in-depth 
case studies) the effectiveness and efficiency of selected IT systems (EESs) supported by the Fiscalis 
programme, it did not collect a very substantial amount of new evidence on the efficiency of other 
(non-EES) activities. Nonetheless, the feedback collected and documentation reviewed confirm that 
the conclusions in the final evaluation of Fiscalis 2020 programme on the efficiency of the non-EES 
activities  supported  by  the  programme  remain  valid,  namely  that  the  collaborative  and  training 
activities are broadly cost-effective. Their share of the overall Fiscalis programme’s budget is small, 
but (as discussed under other evaluation questions) they add significant value by enabling national 
tax administrations to work together and build their capacities and competencies on relevant topics 
of  interest;  in  many  instances,  they  also  support  the  effective  and  efficient  development  and 
application of the EESs. In the absence of any major changes to the way collaborative and training 
activities are implemented, there is therefore nothing to suggest the non-EES activities have become 
any less efficient than under previous iterations of the Fiscalis programme. 

In conclusion, the Fiscalis programme’s governance structure seems to be broadly efficient in 
some  respects  with  a  relatively  clear  structure  for  decision-making  as  laid  out  in  key  documents. 
However,  stakeholders  pointed  out  specific  areas  of  improvement  and  the  programme  faces 
challenges in terms of procedural complexity and transparency in decision-making. It remains to be 
seen whether devolving responsibility for managing the collaborative actions to the Member States 
will  increase  the  efficiency  of  this  aspect  of  the  programme.  Nevertheless,  additions  such  as  the 
MASP-T framework have purportedly improved decision-making procedures and collaboration. 

73 

 
 
 
Table 10. Evaluation matrix – Relevance  

Evaluation questions 

Judgement criteria 

Indicators 

9.  Have  the  objectives  of  the  programme 
remained in line with single market needs, 
and with EU policy needs and priorities?  

10.  Is  the  programme’s  support  for  the 
common  components  of  the  European 
Electronic Systems fit for purpose? If not, 
what adjustments can be made, both during 
the  current  programming  cycle  and  post-
2027? 

11. 

Is 

support 

the  programme’s 

for 
collaborative activities,  training, and other 
actions  fit  for  purpose?  If  not,  what 
adjustments can be made under the current 
programming cycle (2021-2027)? 

▪ 

▪ 

• 

• 

• 

• 

• 

• 

Extent  to  which  the general  and specific  objectives  of 
the programme are still in line with evolving EU policy 
needs and priorities in the area of taxation. 

Extent to which the programme addresses existing and 
evolving needs and political priorities (e.g. Green Deal, 
e-commerce, 
authorities, 
enlargement). 

digitalisation 

tax 

of 

▪  Alignment between the Fiscalis programme’s objectives and EU taxation policies’ priorities, 

as detailed in relevant policy documents. 

▪  Stakeholder feedback on the extent to which the programme responds to EU policy needs and 

priorities in the area of taxation. 

▪  Evidence of shortcomings and misalignment. 

▪  Alignment between the Fiscalis programme’s objectives and EU political priorities. 
▪  Stakeholder  feedback  on  relation  between  the  Fiscalis  programme  and  the  European 

Commission’s priorities. 

Extent to which the Fiscalis programme support for EES 
is appropriate to achieving its objectives. 

•  Alignment between the specific aims of EESs and the Fiscalis programme’s objectives. 
•  Stakeholder feedback on the extent to which the EES are fit for purpose, and any necessary 

changes. 

Extent  to  which  the  programme  meets  the  EU  digital 
needs. 

•  Stakeholders’ views on the comprehensiveness and flexibility of the programme in terms of 

scope of support to EESs. 

Extent  to  which  the  programme  is  in  line  with  the 
evolution  of  overall  EU  policies  and  technological 
developments. 

•  Desk research on programme strategy. 
•  Stakeholder feedback on the alignment between the Fiscalis programme and the evolution of 

technology and EU policy, including feedback on potential improvements. 

to  which 

Extent 
for 
collaborative and other actions is appropriate to achieve 
the programme objectives. 

the  programme 

support 

•  Alignment  between  the  specific  aims  of  collaborative  and  other  actions  and  the  Fiscalis 

programme’s objectives. 

•  Stakeholders feedback on the extent to which the collaborative actions are fit for purpose, 

and any necessary change. 

•  Evidence of fitness for purpose of the LMS. 

Extent to which the programme meets the collaboration 
needs of EU tax authorities. 

•  Stakeholders’ views on the comprehensiveness and flexibility of the  programme’s support 

for collaborative actions, trainings, and other non-IT actions. 

Extent  to  which  the  opportunities  provided  by  the 
programme  have  been  used/exploited 
their 
optimal/maximum capacity, particularly as regards the 
programme’s new eligible action on innovation.  

to 

•  Indicators of use of eligible actions in innovation. 
•  Evidence of the challenges encountered regarding innovative actions (implementation, lack 

of need, etc.). 

•  Indicators of use and uptake of other actions. 
•  Evidence of the reasons for under-use of specific actions. 
•  Stakeholder feedback on opportunities linked to the Fiscalis programme. 

• 

Extent to which the target audience of the programme is 
still relevant. 

•  Stakeholders’ feedback on appropriateness of target audience, by action. 
•  Participation of different types of stakeholders in training activities. 

74 

 
 
Summary response to evaluation questions on RELEVANCE 

Since the relevance of the programme has been extensively assessed and substantiated by previous 
evaluations,  this  evaluation  focused  on  ascertaining  the  extent  to  which  the  conclusions  of  the 
Fiscalis  2020 programme  final  evaluation are still valid. To briefly summarise, that evaluation 
found that the underlying challenges and needs the programme aims to address were still present; that 
the relevance of EESs in the daily operations of both tax authorities and economic operators was high 
and growing; and that collaborative actions were also highly relevant. 

Overall, there was no negative feedback from the stakeholders consulted in this study on the extent 
to which the programme responds to EU policy needs and priorities in the area of taxation, nor of any 
shortcomings or areas of misalignment between the two. Some noted that the Fiscalis programme 
design  is  sufficiently  flexible  to  provide  support  to  address  any  new  or  emerging  priorities,  and 
especially to fund digital solutions that may be needed. This is evidenced, for example, by the creation 
in  2010  of  the  Eurofisc  Network  to  combat  cross-border  VAT  fraud  in  the  EU  and  its  continued 
operation and evolution since then (supported by the Fiscalis programme via several project groups). 
This includes its use since 2019 of the Transaction Network Analysis (TNA) electronic system, which 
was also developed with programme funding. For details, see the case study on TNA. 

On the IT systems specifically (i.e. the common components of the EESs), which is the focus of this 
evaluation question, 86% of respondents agreed (almost half of them ‘fully’) that these correspond to 
their needs. The remaining 14% gave a neutral response; none disagreed. This confirms that, overall, 
the programme’s support for the common components of the EESs is fit for purpose; however, 
the fact that the responses are less ‘enthusiastic’ than for the collaborative actions suggests that there 
may  be  scope  for  some  improvements  in  the  way  they  are  delivered,  or  that  awareness  of  the 
programme’s role in the EESs is still limited. 

According  to  the  national  tax  authorities  that  responded  to  the  survey  (see  Annex  V),  the 
collaborative actions correspond very closely to their needs. Nearly all respondents agreed with this 
statement, and over 70% agreed ‘fully’. Some respondents explained that collaborative actions have 
positive  impacts  on  tax  administrations,  and  that  without  them  there  would  be  a  higher  risk  of 
misalignment  with  EU  legislation  and  less  tax  harmonisation  across  the  EU.  On  the  human 
competency-building / training actions, again a clear majority (86%) of respondents agreed (a little 
over  half  of  them  ‘fully’)  that  these  correspond  to  the  needs  of  EU  tax  administrations  (with  the 
remainder giving a neutral response). This confirms such actions are also fit for purpose, although 
perhaps not to the same extent as the collaborative actions referred to above. Competency-building 
actions that were highlighted as especially well aligned with needs included the e-learning courses 
(described by one respondent as ‘excellent’ in terms of completeness and depth, interactivity, ways 
to track the progress of participants, and use of modern educational technologies), as well as, more 
specifically, Common Event Learning Programme (CLEP) training and workshops for newcomers, 
CLEP trainings on TNA, and CESOP. The case study on the LMS provides further evidence of the 
relevance of this system, which was launched in 2021 as the single repository for the training and 
capacity-building  activities  carried  out  under  the  Fiscalis  programme  (as  well  as  the  Customs 
programme). It was created primarily to address the difficulty that tax administration staff faced in 
locating and accessing training materials. Its centralised, searchable platform solved the problem of 

75 

 
 
scattered  resources  and  improved  awareness  and  uptake  of  EU  training,  particularly  for  training 
coordinators who integrate courses into national curricula. 

76 

 
Table 11. Evaluation matrix – Coherence

Evaluation questions 

Judgement criteria 

Indicators 

12. To what extent is the programme coherent with 
other  EU  initiatives/programmes  with  similar 
objectives?  

13.  To  what  extent  are  the  actions  funded  by  the 

programme internally consistent? 

• 

• 

• 

to  which 

Extent 
consistency with UAFP have been implemented. 

the  recommendations  regarding 

the 

•  Evidence of enhanced coherence between Fiscalis and UAFP / Hercules (e.g. 

via ‘active cooperation or actively sought synergies’).  

Extent  to  which  the  external  coherence  with  other  EU 
interventions  (e.g.  UAFP,  IPA/TAIEX,  RRF,  TSI,  SMP) 
remains high. 

•  Evidence  of  complementarities  or  overlaps  (if  any)  between  the  Fiscalis 
programme  and  support  for  EU  MS  (via  RRF,  TSI,  SMP)  and/or  (pre) 
accession and ENP countries (via IPA, TAIEX). 

Extent  to  which  the  internal  coherence  of  the  programme 
remains high. 

•  Evidence of synergies or contradictions (if any) among actions funded by the 

Fiscalis programme. 

77 

 
 
Summary response to evaluation questions on COHERENCE 

The external coherence of the Fiscalis programme remains high and in line with the findings of 
previous  evaluations,  despite  the  fact  that  the  EU  policy  and  programming  context  has  evolved 
significantly, particularly through post-pandemic measures such as the RRF and the European Green 
Deal. Since the Fiscalis programme exists to support EU policy, this coherence stems mainly from 
the broad alignment of EU tax policy with other policy areas. Yet, it is encouraging that all of the 
initiatives identified showed little risk of overlap with the Fiscalis programme and considerable scope 
for mutual reinforcement. While the evaluation’s focus on a limited number of IT systems – without 
an in-depth examination of specific collaborative actions – means that some examples may not have 
been captured, it is also positive that concrete instances of synergies were found for the European 
Green Deal, RRF and TSI, often in the fields of digitalisation and green taxation. The absence of 
concrete links with the SMP and IPA/TAIEX is not considered problematic, given the different target 
audiences and implementation methods of these instruments. However, mechanisms for coordination 
with  the Hercule component  of the UAFP  (which were  recommended in the previous  evaluation) 
have not been established.  

Table 12. Alignment between the Fiscalis programme and other initiatives 

Initiative 

Overview 

Alignment and potential links with Fiscalis 

Recovery and 
Resilience Facility 
(RRF) 

SG REFORM 

European Green Deal  

Cross-cutting 

that 

The RRF is the EU’s flagship initiative 
for  ensuring 
the  EU  emerges 
stronger  from  the  Covid  pandemic  and 
related  developments.  It  is  worth  EUR 
650  billion,  split  between  grants  and 
loans, 
the 
disbursement  of  funding  to  individual 
‘recovery  and 
countries  based  on 
the 
resilience  plans’  agreed  with 
Commission.  

implemented  via 

and 

The  RRF  is  structural  in  nature  and  targeted  at  individual 
countries rather than collaboration, making it wholly unlike 
Fiscalis  and  much  broader  in  scope.  Potential  links  with 
Fiscalis relate to the extent to which some national projects 
may aim to improve the infrastructure and functioning of tax 
administrations. Moreover, the need to show that challenges 
identified at European and national levels will be addressed, 
including 
reforms, 
tax  policy  will  be 
increases 
implemented effectively, reinforcing the aims of Fiscalis.  

through  administrative  and 
the  chances 

that  EU 

legal 

Rather  than  a  specific  programme  or 
instrument, the European Green Deal is 
an  overarching  political  strategy  aimed 
at reducing net emissions of greenhouse 
gases  to  zero  by  2050  and  decoupling 
economic  growth  from  resource  use.  It 
then  provides  a  framework  for  policies 
and programmes across all policy areas. 

Since  the  Fiscalis  programme  exists  to  support  policy 
development  and  implementation,  its  coherence  with  the 
European Green Deal depends on the alignment of the tax 
policies  it  supports  with  sustainability  objectives  and 
principles. In this regard, the Fiscalis programme could be 
expected to catalyse the design and implementation of green 
tax policies, as specified in Objective 1.1 of DG TAXUD’s 
2021-2024  strategic  plan.  The  Fiscalis  programme  could 
also support sustainability by helping to reduce the carbon 
footprint  of  tax  administration,  e.g.  through  digitalisation 
initiatives.  

Technical Support 
Instrument (TSI) 

SG REFORM 

instrument  provides 

This 
tailored 
technical  expertise  to  Member  States 
across  a  wide  variety  of  policy  areas 
with  the  purpose  of  helping  them  to 
design  and  implement  reforms.  The 
support can consist of strategic and legal 
advice, studies, training or expert visits, 
depending  on  the  needs  of  individual 

The differing implementation methods and objectives of the 
TSI  minimise  the  potential  for  duplication  of  the  Fiscalis 
programme, while its openness to  taxation-related projects 
suggest  a  high  level  of  complementarity  and  potential  for 
synergies.  For  example,  as  highlighted  in 
the  final 
evaluation  of  the  Fiscalis  2020  programme,  a  TSI  project 
could  be  used  to  address  weaknesses  of  a  national 
administration  discovered  in  the  course  of  a  Fiscalis 

78 

 
 
 
Initiative 

Overview 

Alignment and potential links with Fiscalis 

countries,  which  may  relate  to  their 
national plans under the RRF. 

collaborative  action.  Similarly,  TSI  could  also  assist  in  a 
country’s digitalisation efforts. 

Single Market 
Programme (SMP) 

DG GROW and others 

Much bigger (with a budget of EUR 4.2 
billion  for  the  2021-2027  period)  and 
broader than Fiscalis, the SMP provides 
support to a wide range of organisations 
and types of projects in the areas of food 
safety,  consumer  protection,  support  to 
SMEs, ‘a more effective single market’, 
statistics, and standards.  

Instrument for Pre-
Accession Assistance 
(IPA) and Technical 
Assistance and 
Information Exchange 
(TAIEX) 

DG ENEST 

These instruments support accession and 
pre-accession countries in implementing 
the political and economic reforms that 
are needed to meet the requirements of 
EU  membership,  and  to  build  capacity 
and  provide  technical  assistance.  The 
tools  used  include  workshops,  expert 
missions,  study  visits,  review  of  legal 
texts  by  EU  experts,  and  peer  review 
missions.  

The programme strand of ‘effective single market’ relates to 
tax  policy  in  that  it  pursues  projects  to  improve  the 
functioning  of  the  market  on  issues  such  as  anti-money 
laundering  and  the  free  movement  of  capital,  goods  and 
services.  The  scope  for  overlap  is  very  low,  given  that 
taxation forms only a minor focus of the SMP, that project 
outputs  differ  in  nature  from  the  Fiscalis  programme,  and 
that  beneficiaries  are  much  wider, 
including  public 
authorities  but  also  businesses,  NGOs  and  research 
institutions.  Projects  pursuing  goals  could  reinforce  the 
programme.  

In similar manner to TSI for EU MS, the instruments provide 
support  and  expertise  targeting  the  needs  of  specific 
countries and administrations. The scope is broader than the 
Fiscalis programme, but the aims are consistent insomuch as 
IPA and TAIEX address the changes needed to adopt and 
implement EU tax policy. 

79 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table 13. Evaluation matrix – EU added value 

Evaluation questions 

Judgement criteria 

Indicators 

the  different 

14. What is the EU added value 
of 
types  of 
activities  funded  under  the 
Fiscalis programme?  

15.  Overall,  what  is  the  EU 
added  value  of  the  Fiscalis 
programme ? 

• 

• 

• 

• 

• 

• 

• 

• 

• 

Extent to which the IT systems generate benefits and / 
or  cost  savings  beyond  what  could  be  expected  from 
other means. 

Extent  to  which  the  funded  IT  systems  are  needed  to 
implement and apply relevant EU policies effectively.  

Extent  to  which  national  officials  and  economic 
operators fully leverage the possibilities of the Fiscalis-
funded IT systems. 

Extent to which the LMS / Customs & Tax EU Learning 
Portal  generates  added  value  for  administrations, 
economic operators and citizens beyond what could be 
expected from other means. 

to  which  expert 

Extent 
for 
administrations  beyond  what  could  be  expected  from 
other means. 

teams  add  value 

Extent to which collaborative actions are needed for EU 
tax policy development and implementation. 

Extent to which the relevant conclusions of the ex post 
evaluation of Fiscalis 2020 programme remain valid. 

Extent to which exogenous factors, such as the evolving 
policy context, economy and technology have affected 
the role and added value of the programme.  

Extent  to  which  endogenous  factors  related  to  the 
design  and  implementation  of  the  programme  have 
affected its role and added value. 

•  Evidence of the IT systems’ impact on stakeholders. 

•  Evidence of the IT systems’ impact on the implementation of EU tax policy. 

•  Evidence of the IT systems’ impact on the programme’s objectives. 

•  Results of the case studies on selected IT systems, including assessment of usage methods, their costs 
and benefits against the hypothetical counterfactual, and measures to enable usage of the systems. 

•  Stakeholder views on the importance of the IT systems and any discontinuation of support. 

•  Evidence that the LMS has increased awareness and uptake of the human competency activities. 

•  Evidence that the LMS has resulted in efficiency gains compared to the previous approach. 

•  Stakeholder views on the training offer that would be available from the Member States / other forums 

in the absence of the programme.  

•  Evidence  that  the  human  capacity-building  activities  contribute  to  learning  outcomes  and  the 

programme’s objectives. 

•  Evidence of expert teams’ specific strengths and weaknesses compared to other forms of collaboration.  

•  Evidence of expert teams’ contribution to collaboration between tax authorities and the achievements 

of the programme’s objectives. 

•  Evidence of barriers and bottlenecks to the use, effectiveness and / or efficiency of the expert team tool. 

•  Evidence of contribution of the collaborative actions to the development and implementation of specific 

policies, and to the programme’s objectives.  

•  Evidence from the case studies on the balance between in-person and online collaboration, and any 

identified room for improvement.  

•  Evidence  from  the  case  studies  and  programme  assessment  supporting  or  refuting  the  previous 

evaluation’s conclusions. 

•  Overarching assessment and conclusions of the other evaluation questions on EU added value, bearing 

in mind the budgetary split between types of activities. 

•  Identification of relevant exogenous factors and evidence on their implications. 

•  Identification of relevant endogenous factors and evidence on their implications. 

80 

 
 
 
Summary response to evaluation questions on EU ADDED VALUE 

The  survey  feedback  provided  by  national  tax  administrations  on  the  overall  added  value  of  the 
Fiscalis  programme  is  overwhelmingly  positive.  The  majority  of  respondents  reported  that  the 
programme builds trust and leads to convergence between participating tax administrations, that it 
helps to apply EU rules more effectively, consistently and uniformly, and that it means EU legislation 
is  implemented  more  quickly  than  would  be  possible  without  the  Fiscalis  programme  ‘to  a  great 
extent’. A little more nuanced were responses to the question of whether the programme adds value 
above and beyond initiatives at national level,  without any duplication and overlap; even so, over 
90%  of  respondents  believed  it  does  so  to  a  greater  or  lesser  extent.  In  response  to  follow-up 
questions, respondents reported that the Fiscalis programme has had a significant impact on efficiency 
and  international  cooperation,  particularly  through  the  development  and  implementation  of  IT 
systems like VIES and projects such as VAT in the Digital Age, both of which were mentioned by 
multiple respondents. 

The  conclusions  of  the  final  evaluation  of  the  Fiscalis  2020  programme  are  still  fully  valid.  The 
programme, as well as all of the types of systems and activities it funds (see the previous evaluation 
question), provide high EU added value. The Fiscalis programme supports the implementation of 
EU taxation policy and legislation, enabling collaboration, coordination and information exchange 
between national tax administrations that is vital to the effective, efficient and consistent application 
of the former, and thereby helps to enhance the functioning of the internal market, and pursue a variety 
of  taxation  policy  objectives  as  outlined  above  (see  assessment  of  Relevance).  Without  the 
programme, national tax administrations would essentially be left to their own devices when it comes 
to  implementing  EU  taxation  policy  rules  and  mechanisms,  which  would  be  highly  likely  to  be 
detrimental to all of the aspects outlined previously.  

81 

 
 
ANNEX IV. OVERVIEW OF COSTS AND BENEFITS  

The table below summarises the direct and indirect costs and benefits that can be linked to the Fiscalis 
programme, as identified by the evaluation. The nature of the Fiscalis programme – and specifically 
its role in supporting EU taxation policy and legislation across a wide range of domains and topics – 
made it impossible to comprehensively assess the benefits.  In view of this, the interim evaluation 
focused on assessing the implementation of the current iteration of the programme to date, and on 
estimating  (quantitatively  where  possible)  the  specific  costs  and  benefits  of  four  of  the  many  IT 
systems (EESs) that have been developed, upgraded and maintained with financial support from the 
Fiscalis programme. 

The table therefore contains primarily qualitative information on the main costs and benefits of the 
programme for the different groups in question, supported by illustrative quantified examples gleaned 
from the case studies. Overall, it should be noted that, while the exact quantification varies across the 
different systems, all case studies demonstrate that the benefits generally outweigh the costs. 

It should also be noted that the costs in the table do not include the cost of the programme itself to 
the EU budget (EUR 269 million for the 2021-2027 period, over 80% of which is spent on the EESs).  

Table 14. Overview of costs and benefits identified in the evaluation 

Types of impacts  Citizens / consumers 

Businesses 

Administrations 

Quantitativ
e 

Comments 

Quantitative  Comments 

Quantitative 

Comments 

Direct 
compliance 
costs 

Enforcement 
costs 

Indirect costs 

s
t
s
o
C

None 

- 

None 

- 

Cost of staff 
time spent by 
the tax 
authorities of 
participating 
countries on 
taking part in 
and reporting 
on Fiscalis 
programme 
activities. 

None 

- 

None 

- 

None 

None 

E.g. for 
EMCS: 
approx. 1 
FTE for an 
SME, and 
EUR 60 000 
per year for 
contracting a 
third-party 
provider. 

In the case of 
some IT 
systems 
developed with 
the Fiscalis 
programme 
support, costs 
for business 
users to connect 
to / operate the 
system, and 

E.g. for DAC6: 
between approx. 
EUR 4 and 20 
million of total 
additional costs 
incurred to date by 
the tax authorities 
of the 27 EU MS 
(compared with the 
alternative of 
continued bilateral 

In the case of 
some IT 
systems, cost 
for national tax 
authorities to 
develop and 
maintain 
national 
components, as 
well as 
transition to 

82 

 
 
 
 
 
 
 
 
 
 
 
 
 
Types of impacts  Citizens / consumers 

Businesses 

Administrations 

Quantitativ
e 

Comments 

Quantitative  Comments 

Quantitative 

Comments 

Direct 
benefits 

Indirect 
benefits 

s
t
i
f
e
n
e
B

new EES 
versions as and 
when these are 
released. 

The Fiscalis 
programme’s 
contribution to 
more uniform, 
and ultimately 
more effective 
and efficient, 
interpretation 
and 
implementation 
of EU tax law.  
Cost savings 
from being able 
to rely on and 
use IT systems 
(EESs) 
developed, 
upgraded and 
maintained 
centrally. 

Contribution to 
the protection 
of the financial 
and economic 
interests of the 
EU and its MS, 
inter alia thanks 
to the 
programme’s 
contribution to 
the fight against 
tax fraud, tax 
evasion, and 
aggressive tax 
planning. 

exchange of data 
between MS). 

transition to 
new versions as 
and when these 
are released. 

e.g. for TNA: 
approx. 7 staff days 
per month per MS 
saved for data 
collection and data 
processing, 
equivalent to 
around EUR 1.7 
million per year 
overall. 

e.g. for TNA: 
Nearly EUR34 
billion of 
suspicious 
transactions were 
uncovered between 
2021 and 2023 at 
least partly thanks 
to the TNA system. 

None 

- 

None 

e.g. for VIES-
on-the-web: 
between 
approx. 1 and 
50 staff days 
(depending 
on company 
size and 
business 
model) per 
year saved for 
verification 
of VAT 
numbers. 

Indirect 
economic, 
social and (to a 
lesser extent) 
environmental 
benefits from 
the Fiscalis 
programme’s 
contribution to 
the uniform 
implementation 
of EU tax law, 
and to the fight 
against tax 
fraud, tax 
evasion, and 
aggressive tax 
planning. 

Potentially 
significant 
benefits from 
Fiscalis’s 
contribution to 
the uniform and 
efficient 
implementation 
of EU tax law, 
and to the fight 
against tax 
fraud, tax 
evasion, and 
aggressive tax 
planning. 

Cost savings in 
particular from 
access to / use 
of IT systems 
(EES) 
developed with 
the Fiscalis 
programme 
support. 

83 

 
 
 
 
 
 
 
 
 
 
 
 
ANNEX V. STAKEHOLDERS CONSULTATION – SYNOPSIS REPORT  

This section of the report presents the stakeholder consultation activities performed within the context 
of the ‘Study supporting the interim evaluation of the 2021–2027 Fiscalis programme’. The purpose 
of this Annex is to present the stakeholder groups consulted as part of the study and the consultation 
methods, topics covered, as well as the associated limitations. 

1.  Overview of consultation activities 

For the purpose of this study, two main stakeholder consultation activities were conducted: 

1.  Interviews: a total of 84 in-depth interviews were conducted with representatives of national 
tax  authorities,  economic  operators,  and  the  European  Commission.  These  interviews 
provided  qualitative  insights  into  the  experiences  and  perspectives  of  stakeholders  directly 
involved  in  or  impacted  by  the  case  studies  and  the  Fiscalis  programme.  The  interviews 
covered various aspects  of the Fiscalis programmes, and when direct participation was not 
possible, written responses were secured to ensure full coverage and input from all relevant 
parties. 

2.  Targeted  surveys:  three  distinct  surveys  were  conducted  to  gather  quantitative  data  and 
specific  feedback  from  key  stakeholder  groups.  One  survey  targeted  national  Fiscalis 
coordinators  within  the  national  tax  authorities  of  participating  countries.  Additionally, 
concise online user surveys were conducted for two of the case studies, namely VIES-on-the-
web (VoW) and the LMS. These surveys were designed to capture user-specific perspectives 
and  evaluate  the  perceived  added  value,  relevance,  efficiency  and  effectiveness  of  these 
systems. 

The  table  below  provides  a  summary  of  the  consultation  activities  across  the  case  studies  and 
programme assessment. 

84 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table 15. Overview of consultation activities 

Interviews 

Survey 

IT case studies 

VoW 

1 interview with European Commission (DG TAXUD).  

6 interviews with Member States tax authorities (members 
of the SCIT and SCAC committee).  

6  interviews  with  economic  operators  (including  business 
associations and companies).  

Short  survey 
launched  which 
collected  1 248  responses  across 
economic operators.  

EMCS 

2 interviews with DG TAXUD.  

No 

3 interviews with Member States’ tax authorities.  

5 interviews with industry associations. 

6 interviews with economic operators.  

TNA 

5 interviews with representatives from DG TAXUD  

No 

interviews  with  Eurofisc 

15 
liaison  officers  (ELOs) 
(including the  Eurofisc  chair  and  grant  coordinator  for  the 
TNA  expert  team;  the  current  and  former  WF1and  WF2 
coordinators;  the  Europol,  EPPO  and  OLAF  contact  point 
within Eurofisc). 

DAC6 

13  interviews  with  Member  States  (including  members  of 
the  Administrative  Cooperation  on  Direct  Taxation  – 
ACTD).  

No 

Non-IT case studies 

LMS 

8  interviews  with  DG  TAXUD,  the  contractor  responsible 
for developing and operating the LMS and tax officials from 
5 MS. 

A  survey  of  LMS  users  that  was 
promoted on the LMS site itself as 
well  as  by  TSG  members.  The 
survey  was  conducted  together 
with the parallel case study on the 
LMS  for  the  Customs  platform 
and collected 29 relevant replies. 

Programme assessment 

Programme 
assessment 

14 interviews with EU and national-level counterparts. 

Online survey of national Fiscalis 
coordinators (15 responses). 

2.  Programme assessment surveys and interviews 

This section presents an analysis of the responses provided by Member States on experiences with 
and views on the Fiscalis programme.  

The initial input was gathered through a survey developed by the contractor performing the external 
study  and  refined  with  feedback  from  DG  TAXUD.  The  survey  was  launched  on  8  November 
2024and remained open beyond the original deadline of 6 December 2024, with 15 responses received 
by 13 December. It covered 13 Member States and two other participating countries. While this earlier 

85 

 
 
  
 
survey  formed  the  foundation  for  the  consultation,  it  has  since  been  complemented  by  follow-up 
interviews. These interviews were carried out with national Fiscalis coordinators (NFCs) from seven 
of  the  countries  who  had  completed  the  questionnaire  –  allowing  for  deeper  exploration  of  their 
responses – as well as with stakeholders from seven Member States who had not participated in the 
initial survey. The analysis presented in this section draws on both sources.  

Visibility of the Fiscalis programme and dissemination of information  

The focus of this section is on the visibility of the Fiscalis programme within tax administrations, 
based on the insights provided though both the initial survey and the follow-up interviews.  

According  to  the  feedback  collected,  awareness  of  which  IT  systems  are  funded  by  the  Fiscalis 
programme  was  generally  ‘moderate  to  low’  among  tax  officials.  Nine  participants  indicated  that 
officials in their administration are aware ‘to some extent’, while eight described awareness as being 
only ‘to a small extent’. A smaller group – four participants – described a higher level of awareness. 
One participant was uncertain. 

When  asked  about  the  broader  visibility  of  the  Fiscalis  programme  within  their  administrations, 
several  participants  noted  that  awareness  tends  to  be  concentrated  among  senior  management  or 
officials involved in international activities, while regular staff often have limited exposure. Some 
administrations have internal structures or dedicated coordinators that help promote the programme, 
but others reported gaps in communication and a lack of clarity about which initiatives are funded by 
the Fiscalis programme. While a few participants did not view low awareness as problematic, others 
suggested that better internal information sharing (such as brief statements, info sessions, or clearer 
messaging)  could  strengthen  engagement  and  improve  the  overall  impact  of  the  programme. 
Awareness of collaborative actions funded by the Fiscalis programme tends to be higher among those 
directly involved but still remains limited for those officials not engaged in these activities.  

The next question was on sources of information about the Fiscalis programme. A key role is played 
by NFCs: in fact, the majority of respondents highlight that dissemination activities by coordinators 
are one of the main means to receive information on the programme. The PICS platform and direct 
interaction with colleagues in their own administration were cited as frequent sources by over half of 
respondents (respectively 15 and 20 out of 22), together with direct interaction with colleagues within 
one’s own administration (12 out of 22). Other sources seem comparatively less important.  

86 

 
 
 
Figure 15. Sources of information about the Fiscalis programme and its activities 

Source: NFC consultations (no of respondents: 22). 

All in all, the moderate level of awareness reported within tax administration about the role of the 
Fiscalis programme in funding IT systems does not diminish the level of satisfaction on dissemination 
activities carried out by the Fiscalis programme as a whole, with 20 out of 22 respondents reporting 
that they were fully or mostly satisfied. While most respondents appreciate the clarity, efficiency, and 
timeliness of the information shared via the PICS platform and video conferences, some suggestions 
for  improvement  were  made,  such  as  the  need  for  clearer  communication  strategies,  better 
coordination with national coordinators, and more centralised communication efforts, particularly in 
smaller  countries.  These  responses  indicate  that  while  there  is  room  for  improvement,  overall 
satisfaction with how information is disseminated is generally positive. 

Programme management 

The second section of the questionnaire and interviews focuses on management aspects, particularly 
the effort and administrative burden required across different types of activities.  

In general terms, most respondents (19 out of 22) find the overall administrative burden related to the 
Fiscalis programme to be moderate or significant. Significantly, three respondents pointed out how 
the  change  in  programme  management,  with  a  shift  of  management  responsibilities  from  the 
Commission to participating countries, has significantly increased the administrative burden, which 
is  reportedly  particularly  challenging  for  smaller  (and  under-resourced)  national  administrations. 
Issues with the registration process and key implementation challenges were explored in more depth 
through follow-up questions. Respondents pointed out that registration remains more complex than 
necessary,  with  overlapping  systems  (e.g.  ART,  CLEP,  emails),  manual  steps,  and  a  lack  of 
harmonisation. While some tools are still seen as helpful, most respondents expressed a clear desire 
for  simplification  and  better  integration.  More  broadly,  the  financial  aspect  emerged  as  the  most 

87 

 
 
 
significant concern. The rigid budget rules, requiring 80% of the budget to be spent before additional 
funding can be requested, were frequently cited as a key obstacle. Combined with staffing shortages 
and complex financial procedures, these factors have placed increasing pressure on national teams, 
making it harder to plan and manage events effectively. 

The survey then assessed more in detail the burden related to (i) collaborative activities (other 
than expert teams), and (ii) expert teams. The tax administrations of 18 of the 22 interviewees had, 
since  the  start  of  the  current  Fiscalis  programme,  initiated  at  least  one  collaborative  action  (not 
including expert teams). Of those, nine said that the burden connected to initiating a collaborative 
action was moderate, one that it was minor, and another eight that it was significant, but would not 
discourage them from initiating other actions in future. Of the four administrations that did not initiate 
any collaborative action over the period reviewed, one reported that the main reason for this was the 
lack of human resources, while other two are non-EU participating countries.  

The administrative effort required for long-term participation can be a significant motivating factor, 
but the lack of human resources and time is often a key challenge. Tasks like selecting the appropriate 
action  policy  and  engaging  relevant  Member  States  can  be  complex,  and  many  smaller 
administrations  struggle  with  the  increased  workload.  Experts  in  these  administrations  are  often 
overwhelmed by their existing responsibilities, which limits their capacity to initiate or lead new the 
Fiscalis programme activities. While some administrations, such as those hosting groups, can manage 
specific  tasks,  they  are  not  generally  in  a  position  to  initiate  large-scale  events.  Despite  the 
considerable administrative burden, the process can be managed effectively once personnel become 
familiar with it, with the NFC playing a crucial role in guiding colleagues through the process. 

The feedback is overall similar when it comes to participation as a member of the consortium for 
collaborative actions. The feedback provided is generally in line with the previous answer  – most 
respondents (14 out of 22) believe the administrative burden to be moderate or significant, but none 
of them believed that it was to a level that would discourage them from doing it in the future. Similar 
considerations were in evidence when it comes to the administrative burden connected to officers’ 
participations in the actions. Nine out of 22 respondents believe that the administrative burden is 
significant, other nine believe it is moderate and four consider it minor.  

Figure 16. Administrative effort related to collaborative actions (excluding expert teams) 

Source: NFC consultations.  

88 

 
 
 
Of  the  22  interviewees,  only  five  had  previous  experience  as  grant  coordinators  or  project 
managers of an expert team. Of these five, one participant described the burden as moderate, while 
three indicated that, although the burden was significant, it did not discourage them from taking the 
lead in future expert teams. However, one participant noted that the burden was significant enough to 
discourage them from assuming the leadership of future teams.  

Of  the  17  tax  administrations  that  had  never  acted  as  grant  coordinator  or  project  manager,  nine 
identified  insufficient  human  resources  as  one  of  the  main  reasons.  Six  pointed  to  the  excessive 
administrative burden as one of the key factors, while four highlighted a lack of operational need for 
initiating  expert  teams.  Additionally,  two  reported  insufficient  support  or  lack  of  interest  at  the 
national level (hierarchy). A few respondents mentioned that the complexity and engagement required 
to lead an expert team were deterrents, particularly for smaller administrations with limited resources. 
Others preferred initiating project groups or workshops due to the lower administrative burden and 
costs. Additionally, a few highlighted the lack of a specific topic as the main reason for not initiating 
or participating in expert teams, though they would consider it if a pressing issue arose. 

The number of tax administrations whose officials participated in expert teams is instead higher (19 
out  of  22).  The  feedback  on  this  is  possibly  the  most  negative,  with  two  out  of  19  respondents 
reporting that the burden was so significant that it would discourage participation in further expert 
teams. The process of reporting in the activity report tool, ART, is indicated as the most complex and 
burdensome aspect. The administrative burden, however, was not indicated as one of the reasons for 
not participating by the three tax administrations not having taken part in any expert team; instead, 
this appears related to a lack of interest or specific expertise. 

Finally, respondents were asked to compare the overall administrative burden under the current the 
Fiscalis programme funding cycle with the arrangements of the previous cycle. Just over half of the 
respondents (12 out of 22) believe that the current management process is more or much more 
onerous than the previously, while another seven did not experience any change, and only three 
reported improvements. Additionally, respondents noted that NPCs handle more responsibilities in 
the current cycle, including budget management and reporting, which were previously managed by 
the Commission. The introduction of the grant coordinator role has increased national coordinators’ 
independence  but  also  created  coordination  challenges.  As  their  role  becomes  more  operational, 
NPCs face a heavier workload with fewer resources. 

Overall added value of the Fiscalis programme 

The third section of the questionnaire focused on the extent to which respondents believe that the 
programme  has  contributed  to  achieving  results  that  could  not  have  been  achieved  by  national 
administration  acting  on  their  own,  i.e.  generating  EU  added  value.  Most  respondents  find 
collaborative actions useful or very useful (21 out of 22), while 20 out of 22 respondents find expert 
teams useful, though they were slightly less enthusiastic on them than on collaborative actions.  

Respondents specifically emphasised the significant value of collaborative actions and expert teams 
in promoting cooperation, sharing best practices, and harmonising the implementation of EU laws. 
In particular, the CESOP expert team was highlighted for its role in enabling countries to contribute 
to and benefit from these efforts, fostering a unified approach to issues like fiscal fraud and VAT 

89 

 
 
implementation  across  the  EU.  These  actions  are  seen  as  crucial  for  improving  national 
implementation processes and encouraging collaboration among tax administrations. 

The  feedback  on  the  overall  added  value  of  the  Fiscalis  programme  was  also  overwhelmingly 
positive, with the majority of respondents finding that the Fiscalis programme contributed to a faster 
implementation  of  EU  legislation  and  application  of  EU  rules.  The  area  with  the  most  positive 
responses  was  the  extent  to  which  the  Fiscalis  programme  contributed  to  building  trust  and  to 
convergence among tax administrations. However, there was some difference in opinion regarding 
whether the Fiscalis programme adds value beyond national-level initiatives, with a few respondents 
expressing uncertainty or differing views on this aspect. 

Through follow-up questions, respondents reported that the Fiscalis programme has had a significant 
impact  on  efficiency  and  international  cooperation,  particularly  through  the  development  and 
implementation of IT systems like VIES and projects such as VAT in the Digital Age, both of which 
were mentioned a couple of times. Additionally, respondents highlighted the value of workshops, IT 
training,  and  collaborative  networks,  including  those  focused  on  e-invoicing,  which  have  greatly 
supported tax administrations in implementing EU legislation and sharing best practices. 

Figure 17. Fiscalis programme added value for national administration 

Source: NFC consultations.  

Finally, respondents were asked to estimate the extent to which they would still be able to participate 
in collaborative actions under two possible budget scenarios for the programme: the first, entailing a 
reduction in the coverage of expenses, and the second, a reduction in the total elimination of funding 
for collaborative actions. Under a partial reduction scenario, tax administrations would still reportedly 
participate in at least some actions, but in most cases (12 out of 22) with a major reduction, while a 
smaller number of respondents indicated only a minor reduction in participation. In the absence of 
Fiscalis  programme  funding,  three  out  of  22  respondents  would  not  be  able  to  participate  in  any 
action, while another 12 would need to majorly cut back on participation.  

Participants were also requested to indicate which types of action and topic they would prioritise if 
Fiscalis programme funding were reduced. In their responses, several highlighted that they believe 

90 

 
 
 
 
extended collaboration activities (such as project groups) have a higher return on investment than 
workshops, and so they would tend to privilege the former. Some respondents mentioned that they 
would prioritise topics and actions based on national and EU priorities, with some highlighting the 
importance of IT systems and multilateral controls (MLCs). Additionally, some noted that prioritising 
would  be  on  a  case-by-case  basis,  taking  into  account  specific  needs  at  the  time.  Furthermore, 
Member  States  would  reportedly  reduce  the  number  of  participants  by  adopting  a  more  selective 
approach and by participating more in online-only events. 

Validation of and reflections on the previous evaluation 

This final section of the survey investigated the extent to which the conclusions drawn in the final 
evaluation of the Fiscalis 2020 programme (2014-2020) were still valid in the context of the current 
Fiscalis programme (2021-2027). 

The  feedback  provided  by  the  22  respondents  suggests  that  the  majority  strongly  agreed  that  the 
impact of the Fiscalis programme was positive across various areas. Specifically, most respondents 
highlighted  the  programme’s  significant  contribution  to  enhancing  authorities’  administrative 
capacity, the reduction of administrative burdens, and the fight against tax fraud, tax evasion, and 
aggressive tax planning. While the consensus was overwhelmingly positive, some respondents were 
neutral, particularly regarding the alignment of IT systems and collaborative actions with the specific 
needs of EU tax administrations, which indicates some uncertainty.  

Figure 18. Extent to which the conclusions of the previous evaluation are still valid under the current Fiscalis funding cycle 

Source: NFC consultations.  

91 

 
 
 
 
Building  on the previous responses, participants  were  asked to  elaborate  on their experiences and 
reflections regarding the Fiscalis programme. In their replies, respondents consistently highlighted 
the  importance  of  training  actions  funded  by  the  programme,  with  several  specific  systems  and 
training initiatives being frequently mentioned. CESOP and TNA were noted as key IT systems that 
contribute significantly to the fight against tax fraud and support operational efficiency. EU AIAC 
(Advanced  International  Administrative Cooperation), AIAC training and Eurofisc networks were 
also emphasised for their role in enhancing collaboration and sharing best practices, particularly in 
cross-border tax matters.  

In comparison to previous Fiscalis programme cycles, respondents noted improvements in flexibility 
– with Member States now able to initiate their own project groups – and increased use of hybrid 
meetings.  However,  some  respondents  highlighted  the  growing  administrative  burden  placed  on 
national  coordinators  and  the  complexity  of  financial  rules,  particularly  the  80%  pre-financing 
threshold. Moving forward, suggestions for improvement included simplifying the funding process, 
improving  communication,  and  ensuring  timely  and  sufficient  funding  to  better  support  tax 
administrations. Additionally, respondents recommended enhancements to IT systems like PICS and 
emphasised  the  need  for  more  targeted  working  visits  to  address  specific  national  challenges  and 
further improve international cooperation. 

3.  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  EESs  but  also  with  policy  officers.  The 
stakeholder consultations were adapted to each case study’s EES. Additionally, concise online user 
surveys were conducted for two of the case studies, namely VoW and the LMS. More specifically for 
each case study: 

Transaction Network Analysis system (TNA) 
Stakeholders consulted included representatives from DG TAXUD, as  well as  15 Eurofisc liaison 
officers,  including  (i) the  Eurofisc  chair  and  grant  coordinator  for  the  TNA  expert  team;  (ii)  the 
current and former WF1 coordinators; (iii) the current WF2 coordinator; (iv) the Europol, EPPO and 
OLAF contact point within Eurofisc; (v) other ENLOs and ELOs, including members of both WF1 
and WF2, and members of the TNA expert team.  

Directive on Administrative Cooperation (DAC6) 

Consultations  were  conducted  with  Administrative  Cooperation  on  Direct  Taxation  (ACDT) 
delegates representing 13 Member States58. Participants held a range of roles within their national tax 
administrations,  covering  both  policy  and  operational  dimensions  of  DAC6.  These  included 
representatives of the competent authority responsible for implementation, IT specialists involved in 
system development and management of the central directory, and coordinators or analysts supporting 

58  Belgium,  Cyprus,  Denmark,  Estonia,  France,  Germany,  Ireland,  Italy,  Luxembourg,  Netherlands,  Poland,  Spain, 

Sweden. 

92 

 
 
 
 
 
the  day-to-day  application  of  DAC6  requirements.  Some  also  worked  across  multiple  DAC 
frameworks or broader areas of administrative cooperation, providing a wider perspective. 

VIES-on-the-web (VoW) system 

In-depth  interviews  were  conducted,  each  lasting  around  an  hour,  with  officials  of  the  tax 
administrations  (members  of  SCAC  and  SCIT  –  the  standing  committees  on  administrative 
cooperation and on information technology) of six different MS. Where administrations were unable 
to participate in interviews, they provided input through written responses to the interview questions. 
The participants included representatives from Bulgaria (SCIT), Denmark (SCAC), Germany (SCIT, 
written answers), Hungary (SCAC, written answers), Lithuania (SCIT) and Slovenia (SCIT). 

A short survey was launched on the VoW interface to assess the added value of the system, and of 
the ability to  check VAT numbers at  the pan-European level  compared  to  national  interfaces (the 
counterfactual scenario). This survey was designed to capture economic operators’ perspectives on 
the costs and benefits of VoW. Access was provided through a link on the VoW website59, and the 
survey ran for four weeks, from 10 March to 6 April 2025. The questionnaire clarified that VoW is 
not a centralised database of VAT numbers but rather functions as an interface forwarding requests 
to national VIES systems; the clarification was intended to prevent economic operators mistakenly 
attributing blaming the VoW system for issues with national databases and their updates to the VIES. 

A total of 1 248 survey responses were received. Most survey respondents were from Italy (21%), 
Germany (10%), Poland (11%), and the Netherlands (7%), with the remaining respondents more or 
less evenly distributed among the other 23 EU MS. Among the companies surveyed, 36% were micro 
enterprises,  27%  were  small  enterprises,  18%  were  medium  enterprises,  and  19%  were  large 
enterprises. 

In addition to the survey, six interviews were conducted. They were with a key business association 
(one  interview)  as  well  as  with  specific  member  companies  nominated  by  the  association  (three 
interviews with medium and large enterprises in the retail, online platforms and energy sectors). Two 
of  the  interviews  were  held  with  large  companies,  including  a  digital  platform.  This  interview 
approach complemented the survey and allowed for cross validation of survey results. 

Figure 19. How satisfied are you with the following aspects of the VoW? (N = 1 248 respondents) 

Speed of VAT number verification

70%

6%

22%

Ease of use of the interface you most frequently use
(SOAP or web page)

64%

8%

21%

4%

Availability of supporting documentation (e.g. FAQ,
help page, unavailability shifts, technical information)

40%

17%

17%

23%

Satisfied

Neither satisfied nor dissatisfied

Dissatisfied

Don't know

Prefer not to say

59 https://ec.europa.eu/taxation_customs/vies/#/vat-validation 

93 

 
 
 
 
Source: survey of EO 
Survey  respondents  and  interviewees  consistently  highlighted  speed  and  reliability60  as  primary 
benefits of VoW61. Survey data shows that 70% of economic operators are satisfied with the speed of 
VAT  number  verification,  and  64%  appreciated  the  platform’s  ease  of  use  (see  Figure  19). 
Significantly, 53% of survey respondents indicated that verifying VAT numbers took less than one 
minute62, with  an additional 36% stating it takes between one and three minutes. To the question 
‘what  would  you  say  are  the  main  benefits  of  VoW  for  your  business’,  respondents  consistently 
mentioned the platform’s speed: ‘quick check’, ‘fast action’, ‘rapid verification’63. Respondents also 
emphasised the reliability of the platform and its vital importance in ensuring tax compliance64. In 
interviews,  some  economic  operators  expressed  confidence  in  the  accuracy  of  information  from 
VoW, including on company address details. VoW’s availability rate of 99.92% in 2024, consistent 
since  201465,  underscores  its  dependability.  Tax  authorities  also  reported  that  VoW  operates 
effectively, receiving few complaints from national taxpayers, which indicates its stability.  

However, in interviews, some large enterprises, who conduct over 100 000 VAT verifications daily, 
raised  concerns  about  the  service’s  reliability.  These  operators  reported  experiencing  periods  of 
unavailability and highlighted inadequate communication from the European Commission regarding 
scheduled service downtimes, noting instances where planned downtimes were not announced or did 
not align with the provided schedule.  

Excise movement and control system (EMCS) 

Several interviews were conducted to help build the evidence base of the case study. Multiple policy 
officers from DG TAXUD, each with direct and in-depth experience of EMCS, were interviewed to 
help refine the team’s understanding of this complex IT system. These EU-level insights were further 
complemented  by  three  consultations  with  MS  competent  authorities.  These  discussions  helped 
assess  both  the  costs  and  benefits  of  the  current  system  and  the  potential  implications  under  the 
counterfactual  scenario–for  example,  the  impact  if  Member  States  could  no  longer  verify  excise 
information  via  a  central  SEED.  Finally,  the  team  also  spoke  with  11  economic  operators  and 
industry associations from the alcohol and tobacco sectors. These stakeholders shared their views 
on  the  overall  functioning  of  EMCS,  the  EU-level  applications  like  SEED-on-Europa,  and  their 
perspectives on recent system updates such as EMCS phase 4.  

Table 16. Overview of Stakeholder Consultation Strategy 

Stakeholders 

DG TAXUD  

Member State authorities  

# of organisations 
interviewed 

Specific organisations 

2 

3 

N/A 

Czechia, Estonia, Lithuania  

60 In this context, ‘reliability’ refers to the consistent availability and functionality of the online platform, ensuring that it 
operates  smoothly  and  is  accessible  when  needed  by  users,  rather  than  referring  to  the  accuracy  of  the  results  it 
provides. 

61 Open ended survey question ‘What would you say are the main benefits of VoW?’. 
62 Survey question ‘How much time, on average, does it take your staff to verify a single VAT number using VoW when 

used manually?’. 

63 Over 500 survey responses mentioning speed. 
64 Over 400 survey responses mentioning reliability and ensuring compliance. 
65 Availability rate ranging from 99.92 to 99.99% based on data sent by DG TAXUD. 

94 

 
 
 
Stakeholders 

Industry associations 

Economic operators  

# of organisations 
interviewed 

Specific organisations 

5 

6 

Brewers  of  Europe,  CEVI,  CEEV,  EMCA, 
FETRATAB 

AbinBev, 

Ricard, 
Heineken, 
Scandinavian  Tobacco,  Universal  Tobacco, 
TabacNatie 

Pernod 

For this case study, the stakeholder consultation consisted of two main parts: 

Learning Management System (LMS) 

•  A series of interviews with DG TAXUD, the contractor responsible for developing and operating 
the LMS, and tax officials taking part in the TSG from five Member States. The sample took into 
account diversity in terms of both geography and varying levels of engagement with the LMS 
based  on  the  statistics  provided  by  DG  TAXUD,  and  covered  Germany,  Greece,  Ireland, 
Lithuania  and  Spain66.  Eight  interviews  were  conducted  in  total,  based  on  a  semi-structured 
format that used pre-defined questions agreed with DG TAXUD, while also allowing interviewees 
to go into more detail on issues of particular importance to them. While a few additional Member 
States declined to participate due to limited experience with the LMS, the sample was sufficient 
to gather significant insight into the LMS and in line with the approach originally proposed. 

•  A survey of LMS users was promoted on the LMS site itself as well as by TSG members. The 
survey was conducted together with the parallel case study on the LMS for the Customs platform 
and garnered 62 replies, of which 10 mentioned an interest in taxation only and 19 mentioned an 
interest  in  both  taxation  and  customs;  the  remaining  33  respondents  expressed  an  interest  in 
customs only and are not referred to in this report. Of the respondents interested in tax, 15 were 
from tax authorities and 10 from customs authorities, while two represented both tax and customs 
administrations, and just two were from private organisations. Given the relatively small sample 
size, and the fact that most respondents seem likely to have been TSG members rather than course 
participants  as  such,  the  survey  cannot  be  deemed  representative  of  all  LMS  users,  but  it 
nonetheless adds value by providing structured input on a wide range of issues of interest, thereby 
serving to corroborate and expand on the interview findings. In addition, the case study also drew 
on the findings of the survey and interviews conducted for the programme assessment part of the 
evaluation, which included several questions on the LMS in addition to other topics.  

Overall, the methodology was implemented as planned and collected sufficient insight for a robust 
and  meaningful  analysis.  A  limitation  that  should  be  noted  is  that  very  little  input  was  collected 
directly from economic operators / private stakeholders, an important secondary target audience for 
the LMS. In addition, no formal usage targets were set prior to the LMS launch, limiting the extent 
to which it has been possible to gauge success in terms of initial expectations for the platform. Instead, 
the findings have been contextualised based on the views and perceptions of stakeholders, and the 
judgement of the evaluators, transparently explained. 

66 Officials from several other Member States were also contacted but declined to participate due to limited experience 

with the LMS. 

95