529 distributions for attendance at a university in Europe

During the last 20 years, I contributed $25,000 to a 529 account for my son. Its current value is $75,000.

 

He is interested in going to a university in Europe.

 

Let's assume that all of his educational expenses would not be 529-eligible. 

 

If he sent me receipts for his unqualified educational expenses and I reimbursed him from his 529 account, is he responsible for any penalties and taxes, or am I?

 

Regardless, could I include in the distribution an amount to cover the anticipated penalties and taxes and the penalties and taxes on the penalties and taxes included in the distribution?

 

Thanks.