VAT Compliance
The sector is not the problem. The evidence position is.
No trading channel is as data-transparent as online commerce: platform reports, payment data, customs statistics, turnover analytics. That is precisely why the largest VAT fraud case in EU history was run here — and precisely why honest sellers, fulfilment providers and dropshippers end up in machine-generated enforcement grids. This does not put the sector under blanket suspicion: sector risk creates grounds for scrutiny, not guilt. But anyone trading online should know what the data says about them — and be able to evidence their own story.
Why this sector is under scrutiny
The record of the European Public Prosecutor’s Office (EPPO) is unambiguous:
- Operation Admiral (since November 2022): the largest VAT fraud ever investigated in the EU — consumer electronics sold via online marketplaces, the overall complex now put at €2.9 billion; around 9,000 companies and more than 600 individuals mapped. In May 2025 a Lisbon court delivered the first convictions (ten individuals, 13 companies). The EPPO case profiles expressly name marketplace sellers as well as payment and fulfilment providers as the affected environment.
- Admiral 2.0 (28 November 2024): €297 million in damage, marketplace turnover exceeding €1.48 billion, 624 officers, more than 350 searches across 16 countries, over 400 companies under suspicion.
- Escape Room (31 October 2025): electronics carousels through hundreds of letterbox companies. The trigger is the real lesson: one trading company attracted attention because its turnover had grown by more than 800 per cent within three years — data analysis across twelve member states and FIU reports turned that anomaly into an investigation. Unusual growth is now a machine-detectable risk indicator.
- Czechia (3 August 2026): indictment of five individuals and one company over large-scale VAT fraud involving goods imported from China — €17.4 million (CZK 418 million).
- Podlimit (10 April 2026, Bratislava/Liberec) and Dragone (5 March 2025, Rome): import cases around textiles, footwear and e-commerce goods with nine Czech companies under scrutiny, and up to €71 million frozen against a Chinese-controlled consumer-goods network.
Add the system level: payment data has been pooled through CESOP since 2024, platforms report and are liable (Section 25e UStG), and where e-commerce imports are systematically under-invoiced, customs values may be set from EU-wide statistical aggregates — the “lowest acceptable price” (Keladis, January 2026). At the end of 2025 the EPPO reported 981 VAT and customs fraud investigations worth around €45 billion in estimated damage.
The typical constellations
The marketplace carousel (the Admiral type). Seller networks push electronics and consumer goods through platforms while the VAT disappears into corporate webs. Honest sellers trade in the same data space — and are measured against the same patterns: price, growth, payment routes.
Chinese imports with a fulfilment structure. Under-invoiced or untaxed goods sit in EU fulfilment warehouses and ship locally. Whoever provides warehousing, dispatch or payment stands within the chain — as a service provider, not an offender. That difference must be provable.
Dropshipping without touching the goods. The trader sells stock it never sees; import, tax liability and chain-transaction attribution depend on third parties. Legally permissible — but the paper and data trail (who imports, whose IOSS number, who owes tax where?) must hold, or the business model turns into an allegation.
Platform liability and account suspension. Section 25e UStG makes the marketplace a liability debtor — platforms respond with data requests and suspensions. For a seller, suspension is often the economic emergency that arrives before any assessment.
Your red flags
- A supplier ships from EU fulfilment warehouses but cannot evidence the goods’ import and tax trail
- Purchase prices persistently below plausible import costs (customs value, freight, margin)
- Rotating seller identities and shops with identical ranges and contacts
- Payments to third parties or via payment providers with no link to the contracting party
- Third-party IOSS/OSS numbers or inconsistent VAT ID details in the chain
- Your own turnover jumps without an organic explanation — the very pattern the data analytics fire on
- Platform data requests or suspensions hitting your business partners
What affected businesses should do now
If your shop, warehouse or chain is touched by an investigation or a platform measure, the buffer perspective applies: you do not have to explain the network — you must evidence your own trail. Secure transaction data, import and tax records per product range, platform and PSP correspondence and your pricing rationale; answer platform and authority requests in a structured way rather than hastily; clarify OSS/IOSS attributions in writing. The standard comes from supplier due diligence with the red-flag catalogue, a first orientation from the missing trader quick check, the evidence structure from Proof of Check — and the data backdrop is explained under e-invoicing, ViDA, CESOP.
FAQ
The platform has requested documents and is threatening suspension — are we already “suspects”?
No. Platforms are protecting their own liability exposure under Section 25e UStG; their requests follow data patterns, not findings of guilt. What matters is a structured, evidenced reply — it ends most enquiries and simultaneously becomes part of your evidence architecture should an authority ask later.
Can dropshipping be operated safely for VAT purposes at all?
Yes — but only with clean attribution: who imports, whose IOSS/OSS number is used, where does the tax liability arise within the chain? A trader who answers these questions, documented per delivery route, runs a lawful model with provable diligence. Leaving them open means the tax audit answers them later.
What data do the authorities already see about us — today?
Platform reports (Section 22f UStG), CESOP payment data, customs statistics down to the statistical minimum price, plus turnover analytics across member states — Escape Room began with growth of more than 800 per cent. Knowing and being able to explain your own data trail is therefore not optional polish; it is half the defence.
Let us talk about your channel — a free 15-minute consultation: You describe. We assess. You know where you stand. → Confidential first assessment
Start the missing trader quick check — eight questions, traffic-light result, evaluated in your browser only. → Quick check
Acutely affected?
Account suspension, unannounced inspection or dawn raid: emergency — the first 72 hours or call the emergency line directly.