Tax audit lawyer Paris
Area of Expertise

Tax Audit

Notes and reservations — 2026 update :

Whether a procedure is valid (medium and date of notice, nature of the act, taxpayer guarantees, proof of receipt) depends on the facts; this article should not be read as stating an absolute rule.

Comprehensive Support

Defending Your Interests
at Every Step

Being subject to a tax audit is a challenging experience requiring immediate and methodical action. Each step of the procedure involves mandatory deadlines and specific rights that the taxpayer must assert. The intervention of a tax lawyer upon receipt of the first notice guarantees effective defense.

The Firm of Me Jonathan Sémon advises at every stage of tax audit procedures, representing both individuals and businesses before the French tax administration.

Different Forms of Tax Audit

Personal Tax Situation Examination (ESFP, article L. 12 of the LPF) assesses the consistency between the income declared by a taxpayer and their financial situation and lifestyle. It lasts a maximum of one year from receipt of the audit notice.

Bookkeeping Verification (art. L. 13 LPF) examines a company's books and accounting documents. It typically takes place on the company's premises.

Remote Bookkeeping Examination (art. L. 13 G LPF) is a dematerialized procedure allowing the tax authority to verify accounting remotely, without on-site intervention.

Dawn Raids (Tax Searches, Article L 16 B LPF)

Where there are presumptions of tax fraud regarding income tax, corporate tax or VAT — including, since 1 January 2024, inaccurate filings made to obtain business tax credits — the administration may be authorised to search any premises, including private homes, and seize documents. Key safeguards: prior authorisation by court order of the liberty and custody judge (JLD); search between 6 a.m. and 9 p.m. in the presence of a judicial police officer; right to call counsel of one's choice, although operations are not suspended pending counsel's arrival (Cass. com. 9 June 2015, no. 14-17.039). Seizures may cover any medium, including files accessible from on-site computers even when stored on remote servers abroad (Cass. com. 26 Feb. 2013, no. 12-14.772; Constitutional Council, 11 March 2022, no. 2021-980 QPC); the occupant may however refuse to disclose passwords to remote servers, as this falls within a hearing requiring consent (Cass. com. 11 May 2023, no. 21-16.900). Remedies: appeal against the authorisation order before the First President of the Court of Appeal within 15 days of service; challenge to the conduct of the operations within 15 days of delivery of the report; further appeal to the Court of Cassation within 15 days — none of these remedies is suspensive. Seized documents must be returned within six months, and the information gathered may be used against the taxpayer only through a subsequent ESFP or accounting audit (Article L. 76 C LPF).

Procedure Steps

01
Receipt of Audit Notice
The notice must be received before audit operations begin. It specifies the years being audited and your right to be represented by counsel of your choice. It is advisable to consult a lawyer promptly.
02
Audit Procedure
The tax authority examines your documents and may ask questions. The Firm assists you during meetings with the auditor and prepares responses.
03
Rectification Notice
If the tax authority proposes adjustments, it will send you a rectification notice (art. L. 57 LPF). You have 30 days to respond—this deadline can be extended. This response is critical.
04
Appeal to the Commission
If disagreement persists, the taxpayer can appeal to the direct tax and sales tax commission (art. L. 59 LPF). The Firm prepares and presents your case.
05
Tax Litigation
If no agreement is reached, the case goes to administrative courts: administrative tribunal, administrative court of appeal, Conseil d'État (France's highest administrative court). The Firm ensures representation.

⚡ Ongoing Tax Audit ? Time-sensitive matters require prompt action. Each step of the procedure involves specific deadlines — compliance with these deadlines is essential to preserve procedural rights. It is advisable to contact the firm promptly upon receiving the first notice.

Ongoing Tax Audit

The Firm intervenes upon receiving the first notice. Prompt action ensures effective defense across all procedural stages.

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Reference Texts
ESFP: L12, L. 47 LPF
Bookkeeping Verification: L13, L. 47 LPF
Remote Exam: L. 13 G LPF
Rectification: L. 57 LPF
Commission: L. 59 LPF
Taxation d'office: L. 66 LPF
Resources

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Frequently Asked Questions

Frequently Asked Questions

Yes. Article L. 47 LPF ensures that the audit notice explicitly states your right to be represented by counsel of your choice. It is advisable to contact a tax lawyer upon receipt of the notice, even before your first meeting with the auditor. Professional assistance during communications with the tax authority can significantly improve the outcome of the audit.
The notice of proposed adjustment (article L. 57 LPF) is the document by which the tax authority notifies you of the adjustments it proposes to make. It must be reasoned. You have 30 days (extendable upon request) to respond. This response is important for the continuation of the procedure.
Yes. Multiple remedies exist: reasoned response to the rectification notice, petition to the direct tax commission, hierarchical appeal to the auditor's supervisor, contentious claim after collection, litigation before the administrative court. Each remedy has specific deadlines to comply with.
Generally, the tax authority's right to reassess expires at the end of the 3rd year following the year for which the tax is due (standard 3-year statute of limitations, art. L. 169 LPF). This period may be extended to ten years where the taxpayer has not complied with the foreign-asset reporting obligations of articles 1649 A, 1649 AA or 1649 AB of the CGI (LPF, art. L. 169 § 5). For foreign bank accounts (art. 1649 A), the 10-year extension applies only when the aggregate credit balance of the undeclared accounts has exceeded 50,000 € at any time during the relevant year (LPF, art. L. 169 § 5 in fine; BOFiP BOI-CF-PGR-10-50).
A personal income tax examination (ESFP) cannot exceed one year from receipt of the audit notice. An on-site books and records examination is limited to 3 months for small businesses whose turnover does not exceed certain thresholds (art. L. 52 of the French Tax Procedural Code); this period may be extended to six months in case of serious accounting irregularities. Businesses above those thresholds are not subject to this statutory limit. The one-year maximum applies to the personal income tax examination (ESFP, art. L. 12 LPF).
It is advisable to seek professional representation. Contact a tax lawyer promptly. The notice mentions your rights: assistance by counsel, request to postpone the first meeting, taxpayer charter. Your lawyer will analyze the scope of the audit and prepare defense strategy before the first exchange with the auditor.
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