#Tax Audit in France: Lawyer in Paris

A tax audit lawyer defends the company and its director from the moment the notice of tax audit is received. They check that the procedure is lawful, prepare the discussion with the auditor and challenge unjustified reassessments. Hashtag Avocats acts in Paris at every stage of the audit, from the first letter to litigation before the tax court.

What is a tax audit in France and who can be audited?

A tax audit covers all the procedures by which the tax authorities check that tax returns are accurate. Any company and any individual can be audited, whatever their size. The form of the audit varies according to the taxpayer’s situation and what is at stake in the case.

Desk audit and remote audit of the accounts

A desk audit (contrôle sur pièces) is carried out from the tax authorities’ offices, without a visit to the taxpayer. The tax office compares the returns with the information it already holds. A remote audit of the accounts (examen de comptabilité) follows the same logic at a distance: the company sends its standard audit file of accounting entries (FEC) and the tax authorities analyse it from their premises. These audits often lead to a simple request for clarification, sometimes to a proposed tax reassessment.

On-site audit of the company’s accounts

An on-site audit of the accounts (vérification de comptabilité) in principle takes place at the company’s premises. There, the auditor compares the accounts with the returns filed, through an oral and adversarial discussion. It is the most in-depth form of audit, and the one that requires the most rigorous preparation. For individuals, the equivalent is the in-depth review of an individual’s overall tax position (ESFP).

Tax audit in France: how many years back can the tax authorities go?

The standard limitation period

For income tax and corporate income tax, the right of reassessment can be exercised until the end of the third year following the year for which the tax is due (Article L169 of the French Tax Procedure Code, Livre des procédures fiscales). In practice, an audit started in 2026 may cover income or profits for 2023, 2024 and 2025.

When the period is extended

The same Article L169 extends this period to ten years in several cases: carrying on an undisclosed activity, failure to declare accounts, capitalisation contracts or trusts held abroad, or a false tax domicile abroad. For foreign accounts, the extension does not apply where the taxpayer shows that their total balance did not exceed €50,000 during the year. How the situation is classified therefore matters a great deal: three auditable years or ten.

How the audit unfolds, from the notice of tax audit to closure

An on-site audit of the accounts or an ESFP cannot begin without a notice of tax audit (avis de vérification) being sent or handed over beforehand (Article L47 of the French Tax Procedure Code). This notice specifies the years under audit. On pain of nullity of the procedure, it mentions your right to be assisted by an adviser of your choice.

The audit operations themselves follow: review of documents, requests for justification, exchanges with the auditor. The audit ends either with a notice that no reassessment will be made, or with a reasoned proposed tax reassessment (proposition de rectification). This document opens the written adversarial phase: you have a period in which to submit your observations, which the tax authorities must examine and answer.

Safeguards for the audited taxpayer

The audit procedure is governed by safeguards whose breach may lead to the tax assessed being cancelled. The main ones are as follows:

• the Charter of the rights and obligations of the audited taxpayer, available on impots.gouv.fr, whose provisions are binding on the tax authorities;
• the right to be assisted by an adviser, mentioned in the notice of tax audit on pain of nullity;
• the oral and adversarial discussion with the auditor during the on-site audit of the accounts;
• internal appeals in the event of continued disagreement: the auditor’s superior, then the departmental liaison officer (interlocuteur départemental);
• the possibility of referring certain questions of fact to the Commission for Direct Taxes and Turnover Taxes.

Your lawyer checks point by point that these safeguards have been respected. A clearly identified procedural defect can bring down all of the additional assessments.

After the audit: proposed tax reassessment, appeals, litigation

Receiving a proposed tax reassessment is not the end of the discussion, but its beginning. Written observations, supported in law and in fact, can lead the tax authorities to drop or reduce additional assessments. If they are upheld, a formal tax claim and then referral to the court remain available. We also assist you before the court with our team dedicated to business tax litigation (in French).

Financially, additional assessments carry late-payment interest of 0.20% per month (Article 1727 of the French Tax Code, Code général des impôts), to which surcharges may be added depending on the seriousness of the failures. A tax settlement (transaction fiscale) can sometimes be negotiated on penalties. Voluntary regularisation, before any audit, halves late-payment interest: our page on voluntary tax disclosure explains this process. Where the case carries a criminal risk, our team works alongside our tax fraud practice.

Why be assisted by a tax lawyer from the notice of tax audit onwards?

The positions taken in the first exchanges with the auditor shape the rest of the case. A document sent without analysis, an imprecise answer or a missed deadline is hard to put right. The lawyer structures the strategy from the outset: scope of the audit, weak points, documents to gather, arguments to keep for the adversarial phase. Our team of tax lawyers defends companies and their directors alike; their interests sometimes need to be distinguished. Every situation is different and calls for its own analysis.

FAQ

Tax audit: how many years back?

Three years as a general rule for income tax and corporate income tax: the right of reassessment can be exercised until the end of the third year following the year of taxation. The period rises to ten years in the event of undisclosed activity, undeclared foreign accounts or a false domicile abroad.

What exactly is a tax audit?

It is the tax authorities’ check that your returns are consistent with your actual situation. It takes the form of a desk audit, a remote audit of the accounts or an on-site audit of the accounts at the company. It may end without any reassessment.

Who can trigger a tax audit?

The decision lies with the tax authorities. They schedule their audits on the basis of data analysis, cross-checks between returns, inconsistencies detected or information received from third parties. No company is immune from an audit, even in the absence of any irregularity.

Why is my company being audited?

The most frequent triggers are discrepancies between the returns and the data held by the tax authorities, unusual changes in profits, repeated VAT credits or the business sector. The audit may also be part of the tax authorities’ general audit programme, without any particular irregularity.

Should you answer the auditor yourself?

You have the right to, but every answer has consequences for the case. The notice of tax audit reminds you of your right to be assisted by an adviser: exercising it from the start makes it possible to structure the exchanges, protect the procedural safeguards and prepare any challenge.

Official sources

• Article L169 of the French Tax Procedure Code (Livre des procédures fiscales), limitation period for income tax and corporate income tax: Légifrance (in French)
• Article L47 of the French Tax Procedure Code, notice of tax audit and assistance by an adviser: Légifrance (in French)
• Article 1727 of the French Tax Code (Code général des impôts), late-payment interest: Légifrance (in French)
• Charter of the rights and obligations of the audited taxpayer: impots.gouv.fr (in French)
• BOFiP, Tax audit series, information for the taxpayer and notice of tax audit (BOI-CF-PGR-20-10): bofip.impots.gouv.fr (in French)

Law verified as at 5 October 2026. This content provides general information and does not constitute legal advice. Every situation is different: contact our team to have your case reviewed.