New Technologies in VAT Reporting, Collection and Auditing: Legal Opportunities and Challenges (VATTECH)

This project investigates the legal opportunities and challenges of the use of technology-based tools in VAT administration as means for combating VAT fraud, facilitating compliance and supporting the proper functioning of the harmonised EU VAT. VATTECH is a MSCA Individual Fellowship research project, funded by the European Commission.

The advancement of new technologies – including big data analysis and complex algorithms – has the potential to significantly reducing VAT fraud and facilitating a proper functioning of the EU VAT system. Fraud erodes budgets of states and leads to distortions of competition. It affects honest businesses and consumers and violates the very fundaments of the EU Internal Market.
On the other hand, technology-based tools and their use by public administrations cause risks of infringement of taxpayers’’ rights including the right to fair trial, the right to privacy and the right to property. The objective of VATTECH is to evaluate technology-based tools in the light of the EU legal framework and the protection of taxpayers’ rights. The ambition is to provide important, new insights into the EU VAT system and to contribute to the improvement of the tools to combat VAT fraud, administrative cooperation and exchange of information between and across the EU MS.






  • What are the technology-based tools for combating VAT fraud and what is the best practice (in the light of their purpose, the legal framework in the EU and the protection of taxpayers’ right)?
  • What are the challenges to the taxpayers’ rights and the EU law and how can they be remedied?
  • How could the EU VAT system benefit from technology-based tools and should  coordination/harmonization in that field be recommended?


  1. Technology-based tax tools and their role in combating VAT fraud and supporting the functioning of the EU VAT.

MS have procedural and institutional autonomy as to the prevention of breach of VAT law, while being obliged to take all measures appropriate for ensuring collection of all the VAT due on their territory and must fight against tax evasion and tax fraud. Technology in VAT administration has been used by several EU MS as means of combating fraud and streamlining compliance by taxpayers. MS through their discretion or certain derogations granted under the Directive 112/2006/EC (VAT Directive) have in recent years introduced electronic reporting tools, real-time invoice clearance, split-payment mechanism and developed algorithm based data analysis and risk assessment tools to detect and prevent fraud. The first phase of VATTECH aims at setting out the central premises and scope of the project by focusing on identification and selection of relevant tools of VAT reporting, auditing and collection based on new technologies adopted in the recent years individually by states and clarifying their purpose and functionality.
This phase has analytically descriptive character and is of instrumental importance for phase 2 and 3. As the starting point, tentatively the list of tools to be researched includes SAF-T, real time VAT reporting and electronic invoicing, split-payment mechanism, as well as transaction network analysis tools, such as Polish “STIR”.
To clarify functionality of the tools and their role in combating VAT fraud a legal dogmatic methodology combined with comparative legal analysis will be used.

  1. The challenges and opportunities of technology-based tax tools in the light of taxpayers’ rights and the existing EU legal order

Phase 2 will regard the central part of the project that is analysis of the selected tools and their underlying legislations. Legal dogmatic method will be also used to evaluate the tools in question from the perspective of their consistency with the legal character of VAT as general, indirect tax on consumption, the current legal framework as established by the VAT Directive and other relevant provisions of EU law. Integrity of the VAT system and EU legal order will be taken in consideration when formulating recommendations as to a preferred tools and legal guarantees concerning design, functioning and use of the tools by the MS.  The evaluation will also focus on the suitability of the researched tools as to their objective, and implications of their introduction for tax authorities and business alike. The core elements of effective tax administration consist of optimization of compliance in a cost-effective manner, minimizing burdens on taxpayers and building and maintaining the trust of taxpayers. Elements of empirical qualitative research will be relied on when analyzing functioning of the technology tax tools based on official documents published by institutions representing national business community and publicly available administrative decisions. The final evaluation allowing for identification of the opportunities and challenges will consist of assessment of the tools in the light of the principles of their suitability for combating VAT fraud and non-compliance on one hand, and the principle of legal certainty, fundamental rights, including the right to privacy, data protection and right to fair trial, which have been identified as potentially interfering with the technology based effective methods of combating VAT fraud. The ambition is also to consider how the identified challenges can be remedied, for example, through a restatement and redefinition of taxpayers’ rights and their enforcement in the context of new technologies.
A functionally comparative analysis of the tools used in different national jurisdictions is relevant considering that a common system of VAT based on to a large extent harmonized rules exist in the EU. The analysis is expected to enhance understanding of benefits and challenges relating to particular technological solutions. In that part the study is expected also to bring about a deeper understanding of how MS which have not introduced the modern tools of VAT collection, such as Denmark, could further improve their tax collection. To collect relevant national sources of law and scholarly articles, as well as to conduct the 2-3 short research trips will be planned to academic institution abroad. 

  1. Potential coordination/harmonization of the tools at the level of the EU

Phase 3 will focus on the opportunities and challenges of a coordinated/ harmonized approach to the technology-based tools and their potential for enhancing administrative cooperation between the MS. In that context, it will be also considered whether and how technology could not only support the existing EU VAT system but also provide an opportunity for more far-reaching amendments to the system. Fragmentation of regulation in the EU significantly increases costs for businesses trading cross-border and distorts competition by creating incentives for businesses to establish in MS with less stringent compliance requirements or control.  Furthermore, the potential of the technology-based tools is not fully exploited due to geographical limitations of their application. A coordinated or harmonized approach could bring about simplification and greater certainty for taxpayers, could increase mutual trust by the MS and make fulfilment of their mutual obligation relating to tax collection more effective. On the other hand, harmonization entails challenges due to differences in constitutional laws of the MS, for example different scope of the principle of transparency and secrecy and privacy, and different legal cultures. The analysis in this phase will focus first on identifying the main weaknesses in the existing EU legal framework for VAT administrative cooperation. Secondly, building on conclusions from phase 1 and 2 and taking into consideration the principle of proportionality and subsidiarity, system recommendations will be formulated as to optimal rules on the level of the EU.



  • 15.11.2023 – post-Congress seminar (online), IFA (International Fiscal Association) Poland: Presentation and summary of the YIN Seminar “Consumption Taxes and the Digital Economy: Where Are We Now”.
  • 10.10.2023 – Presentation “VAT, technology and human rights” at the University of Copenhagen for the University employees and external guests (Tax authorities and VAT specialists from business side) – presentation and discussion on the main results of VATECH project;
  • 04.10.2023 – A seminar for VAT experts at the Danish Chamber of Commerce – presentation of the VAT in the Digital Age proposal of the European Commission;
  • 19-23.06.2023 – THE 15th GREIT (Group for Research on European and International Taxation) Lisbon Summer Course: EU & International Tax Recent Developments, Speaker at the session on VAT;
  • 16.05.2023 – teaching on “VAT reporting and E-invoicing in the EU” at the Advanced Master’s (LL.M.) in International Taxation at the University of Amsterdam;
  • May 2023 and November/December 2022 – teaching on VAT and e-commerce at Tax and VAT law course, University of Copenhagen;


  • “The end does not justify the means: On how the secondary EU law infringes the primary EU law in the light of the recent judgments of the CJEU”, INTERTAX, vol 51, Issue 8/9 (2023) (double blind peer-review)

  • “MV - 98. Cumulation of administrative penalties of a criminal nature for the same act.” Highlights & Insights on European Taxation, Issue 9 (2023) (peer-reviewed)

  • “Secure DRR to Tackle EU VAT Fraud” in Weber, D. “The Implications of Online Platforms and Technology on Taxation”,  International Bureau of Fiscal Documentation (IBFD) (2023)
  • Papis-Almansa M. “VAT in the Digital Age. Real-time digital reporting based on e-invoicing for businesses”,  Highlights & Insights on European Taxation, Issue 2 (2023).
  • Papis-Almansa, M., Lamensch, M. & Jafari, S. “European Union - Proposal for a Secure Digital Reporting Standard for Intra-Community Transactions”, International VAT Monitor vol 33, Issue 6 (2022)
  • Papis-Almansa, M., “The use of new technologies in VAT and taxpayers’ rights” in  Kofler, G., Lang, M., Pistone, P., Rust, A., Schuch, J., Spies, K., Staringer, C. & Kuniga, I. (eds.). CJEU: Recent Developments in Value Added Tax 2021 (Linde 2022), Linde Verlag Wien, p. 1-32 (2022);  Pre-print available at SSRN





























Name Title Image


Horizon 2020 and Marie Skłodowska-Curie Actions logo

New Technologies in VAT Reporting, Collection and Auditing: Legal Opportunities and Challenges (VATTECH); Marie Skłodowska-Curie Actions, Individual Fellowship has received funding from the European Commission. 

Project: New Technologies in VAT Reporting, Collection and Auditing: Legal Opportunities and Challenges (VATTECH)
(Proposal ID 101028296)

Period: 1 October 2021 – 30 September 2023


Marta Agnieszka Papis-AlmansaPI Associate Professor
Marta Agnieszka Papis-Almansa

South Campus,
DK-2300 Copenhagen S