A tax audit may affect any business or individual and may result in reassessment. We assist you from the accounting review stage through to litigation, negotiating with the tax authorities and defending your interests before the courts.
The Personal Tax Audit (ESFP) is a procedure through which the tax authorities verify the consistency between your declared income and your lifestyle. You are officially notified by a verification notice.
Any individual whose income and lifestyle are subject to consistency checks by the tax authorities.
The ESFP is governed by specific safeguards to protect your rights, including:
Without proper support, an ESFP can lead to significant reassessments, surcharges (10% to 80%), and late payment interest. For example, in 2022, amounts recovered after tax audits reached €14.6 billion, and in 2024 they exceeded €16 billion—highlighting the importance of preparation.
We assist you from the very beginning of the audit by:
An accounting audit is an on-site inspection by the tax authorities to ensure that a company’s accounting records are accurate, reliable, and consistent with the tax returns filed.
Mainly businesses subject to accounting obligations:
It does not apply to income without accounting obligations (e.g., rental income).
Irregularities may result in:
The auditor must respect taxpayers’ rights, and failure to do so may invalidate the procedure. Without proper advice, you risk costly reassessments and penalties (up to 80%). Penalties range from 10% for simple errors to 80% for deliberate breaches or fraud. Late payment interest accrues at 0.20% per month.
We support you throughout the entire process by:
Tax negotiation with the authorities aims to reach an amicable solution in cases of audits, reassessments, or reporting difficulties. It may involve discussions to reduce an adjustment, requests for discretionary relief from penalties, arrangements for payment deadlines, or the conclusion of a settlement.
Any individual or business facing a tax dispute and seeking an amicable resolution.
Well-managed negotiation can:
Poorly prepared negotiation, however, may result in unfavorable commitments.
We assist you at every stage by:
The tax authorities may send requests for information or clarification regarding items reported or transactions carried out, often as a preliminary step before a more in-depth audit. These requests may relate to the origin of income, the nature of an expense, etc.
Any individual or business receiving a request for clarification from the tax authorities.
An incomplete, late, or inaccurate response can have serious consequences, such as triggering more intrusive procedures (accounting audit, ESFP) or automatic taxation. In 2023, nearly one million desk audits of income tax returns were conducted, representing a 37% increase compared to the previous year, underlining the frequency of such requests.
We assist you from the moment you receive a request by:
When tax fraud is suspected, the authorities may, under certain conditions, carry out searches and seizures (documents, electronic files, etc.), including in private premises. These operations are strictly regulated:
Any individual or business suspected of tax fraud and subject to investigation.
These operations interfere with privacy and individual freedoms, which is why they are strictly regulated. Breaches of the rules may render the procedure invalid. If not properly managed, they may result in massive reassessments and criminal prosecution. The cost of tax fraud in France is estimated between €60 and €80 billion per year, justifying the strictness of these measures.
We intervene immediately to:
A tax claim (réclamation contentieuse) is a formal procedure allowing you to challenge a tax assessment (calculation error, missed exemption, incorrect interpretation). It may relate to CIT, VAT, CET, PIT, etc. The deadline is generally two years from collection or payment.
Any individual or business wishing to contest a tax assessment.
It is the official channel for asserting your rights. Respecting deadlines is crucial for admissibility. Specific points of vigilance exist, particularly for CVAE.
We assist you in preparing and filing your claim, ensuring compliance with deadlines and formalities to maximize your chances of success.
The Administrative Court is the first instance of the administrative judiciary competent for tax disputes. After a tax claim has been rejected (fully or partially) or has remained unanswered for more than 6 months, you may file a petition before the court. The procedure involves the filing of briefs, a hearing, and the possibility of appeal.
Any individual or business whose tax claim has been rejected by the tax authorities.
Filing an appeal before the Administrative Court is a key step in challenging an unfavorable tax decision. A properly managed procedure is crucial to defend your interests and obtain the annulment or reduction of the contested tax.
We assist you at every stage by:
The Judicial Court is competent for certain tax disputes, particularly those relating to registration duties, real estate wealth tax (IFI), or local direct taxes (property tax, housing tax). The procedure involves issuing a writ of summons, filing pleadings, attending a hearing, and the possibility of appeal.
Any individual or business involved in a tax dispute falling under the jurisdiction of the Judicial Court.
As with the Administrative Court, an appeal before the Judicial Court is essential for challenging a tax assessment. The specific nature of judicial proceedings requires particular expertise to effectively defend your rights.
We support you at every stage by:
An appeal in cassation is an extraordinary remedy brought before the Court of Cassation (for decisions of the Judicial Court) or the Conseil d’État (for decisions of the Administrative Court). It does not concern the facts, but only the application of the law by the trial judges. Its purpose is to verify whether the challenged decision complies with legal rules.
Any individual or business seeking to contest a decision issued on appeal by an administrative court of appeal or a judicial court of appeal, on points of law.
An appeal in cassation is the final level of recourse. It ensures uniform interpretation of the law. A favorable decision may result in the case being referred back to another court of appeal for reconsideration on the facts, or in the definitive annulment of the contested ruling.
We guide you through this complex procedure by:
A desk tax audit is a review carried out by the tax authorities from their offices, without visiting the taxpayer. It involves examining the tax returns, documents, and information you have filed (income tax returns, VAT returns, etc.) and cross-checking them with information available to the authorities (bank data, third-party information, etc.).
All taxpayers, both individuals and businesses, may be subject to a desk audit. It is the most common form of tax audit.
Although less intrusive than a Personal Tax Audit (ESFP) or an on-site accounting audit, it may still result in tax reassessments if irregularities are found. It is crucial to respond accurately and with proper documentation to the authorities’ requests to avoid escalation into a more burdensome procedure. Proper preparation and understanding of the authorities’ expectations are essential.
We assist you in analyzing the authorities’ requests, preparing responses, and providing the necessary supporting documents. Our goal is to secure your position and minimize the risk of reassessment from the very first stage of the audit.
The main types of tax audits are the on-site accounting audit (in the company’s premises), the remote accounting review (through submission of digital accounting files – FEC), and the ESFP (Contradictory Examination of Personal Tax Situation) for individuals. Each procedure follows a specific timetable and is governed by taxpayer rights (charter of audited taxpayers).
In principle, the reassessment period is 3 years (year N + 3). It is extended to 10 years in the case of hidden activity, and to 6 years for registration duties or real estate wealth tax (IFI). These time limits require particular vigilance in archiving and documenting transactions.
Yes. The taxpayer may submit written observations, request a contradictory meeting, and refer the matter to the departmental interlocutor in case of disagreement. In certain situations, a tax settlement is possible to reduce penalties (up to 40% if good faith is acknowledged).
The taxpayer may:
Tax reassessments are accompanied by late payment interest (0.20% per month, i.e., 2.4% per year) and surcharges:
Good preparation involves:
In the event of an audit, responsiveness and support from a tax lawyer significantly increase the chances of success.