Background The European Public Prosecutor’s Office (EPPO) recently opened a criminal investigation against a non‑EU multinational company for alleged VAT evasion amounting to EUR 80 million. The company operates an online platform through which retailers sell directly to consumers across Europe. Assuming that VAT obligations rested with individual traders, the company did not file VAT returns in Germany. The German tax investigation office, however, classified the business model as proprietary trading and therefore considered the…