Europe knows all about your VAT transactions – Do You?

bild-fur-blog-grahamThere are headlines most weeks, if not days, telling us all about the different European jurisdictions where submission of transactional VAT data is mandatory. What frustrates me is that these stories tend to recycle the number of EU states who have mandatory regimes, without explaining which countries they are talking about, or which regulatory submission.

“There are 6 EU SAF-T states, but 2 also have an e-audit regime” is one of the most frequently recurring. However, I have seen articles claiming 9 or 10 transactional eFiling territories. Having gone back to the individual EU/EEA countries concerned to look at the legislation, I suggest that there are actually at least 14 countries across Europe who are (or will be by 1 July) collecting and analyzing this data.

Traditional VAT/SAF-T

Austria, France, Lithuania, Luxembourg, Poland & Portugal all have existing SAF-T based eFiling regulations for VAT transactional data. With Norway joining them this year, we have 7 SAF-T territories in Europe / EEA.

SAF-T has historically been used to provide more detailed, transactional, data about VAT subsequent to the filing of quarterly or monthly summary form-level data.

Invoice Approval or Submission

A second group of countries require the submission of Invoice data, either in real-time or following on shortly after the event. Czech Republic & Slovak Republic have long-standing regulations here, and Italy, Hungary & Spain join them this year. Italy from 1 January, Hungary & Spain from 1 July. That gives us 5 more territories.

You can debate the point whether each submission standard in this category is SAF-T or not; I’m not that concerned about what you call it. I am grouping these on the basis that the regulation comes from Invoicing, rather than VAT.


The Benelux countries have, for a number of years, shared cross-border VAT information within a project called Transactional Network Analysis, to identify and prevent Carousel Fraud.

Public statements have suggested that up to 10 countries are a part of the TNA group, but only the Benelux 3 are clearly identified. Luxembourg is a part of our Traditional VAT/SAF-T group, but we can definitely add Belgium & Netherlands to our list of EU states collecting sufficient transactional data sufficient to perform analytics. The others may be part of our SAF-T or Invoice groups, but we cannot be certain.

Data Analytics

With these regulatory submissions, the authorities have detailed submissions about each individual transaction; that’s as much information as your own organisation holds on those transactions. They also have large, and growing, data analytics groups of their own.

If your organisation is not performing data analytics on your own VAT & Invoice data, it will not be long before the regulators are asking you questions that you do not want to hear; they can compare your data with all the other data they collect, and exchange, and know more about your companies data than you do!


This article was written by Graham Tilbury, Tax and Accounting Technology Guru @ PwC Zurich.

If you have any questions, please do not hesitate to contact him on +41 58 792 24 19 or

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