#Tax Lawyer in Paris

Tax lawyer in Paris for individuals and businesses

French taxation weighs on every major business decision: selling a company, passing on wealth, structuring an investment, a tax audit or a dispute with the tax authorities. Poor planning quickly leads to a tax reassessment, penalties and sometimes lengthy litigation. Our firm assists business owners, investors and individuals, in Paris and throughout France, combining strategic advice with litigation defence.

This page sets out our approach to tax law: our areas of practice, how we assist you in a tax audit, our defence in tax litigation and criminal proceedings, and the wealth planning tools permitted by law. Every situation is different, and we review yours against the legislation in force at the time you instruct us.

The firm’s Corporate/Tax practice is headed by Maître Harry Allouche, a lawyer (avocat) admitted to the Paris and Québec Bars. Looking for a tax lawyer, a tax attorney or a lawyer in tax law? You deal with the same person: a lawyer admitted to the Bar, bound by professional secrecy, who meets you at our offices at 51 avenue Franklin Delano Roosevelt, Paris 8e.

Tax lawyer for individuals: income, wealth, inheritance

Individuals usually consult us at a specific moment: a sale, a gift, a move abroad or a letter from the tax authorities. Here are the most common situations, each covered on a dedicated page.

• Income tax, foreign-source income, capital gains on real estate and securities: our personal taxation page;
• Real estate wealth tax (IFI), gifts, inheritance and estate planning: our wealth protection (in French) page;
• Moving abroad, returning to France, accounts and policies held outside France: our tax and expatriation page;
• Reporting and taxation of crypto-assets: our crypto tax lawyer page.

Tax lawyer for businesses and their directors

For businesses, tax considerations shape almost every decision: choice of structure, directors’ remuneration, external growth, sale or transfer. We advise on corporate income tax, VAT, groups and holding companies.

• Audits and disputes: business tax audits and business tax litigation (in French);
• VAT: our VAT lawyer page;
• Holding companies and groups: our active holding company page;
• Directors’ remuneration and wealth: our tax planning for company directors page;
• Cross-border transactions: our international tax lawyer page.

Sales and business transfers are covered further down, with the contribution and sale (apport-cession) and Dutreil pact rules applicable since 21 February 2026.

The role of a tax lawyer in your wealth strategy

A tax lawyer deals with all the taxes and duties that apply to individuals and companies: income tax, corporate income tax, VAT, registration duties, real estate wealth tax, social levies. They advise, draft sensitive documents (shareholders’ agreement, contribution of assets, gift, intra-group agreement), secure transactions with an advance tax ruling where necessary and argue cases before the tax and criminal courts.

What sets them apart from a chartered accountant is their mission: a lawyer practises with full independence and is bound by professional secrecy, established by Law No. 71-1130 of 31 December 1971. This secrecy covers written and oral consultations and, in principle, can be relied on against both the tax authorities and the courts, which makes exchanges with a lawyer particularly protective when a dispute is looming.

Our tax practice covers personal taxation, tax planning for company directors, group taxation and equity transactions. We rely on the legislation, the administrative guidance published in the Official Public Finance Bulletin (Bulletin officiel des finances publiques, BOFiP) and recent case law of the administrative courts and the French Constitutional Council (Conseil constitutionnel).

Tax lawyer, chartered accountant, notary: who does what?

“Tax adviser” (conseiller fiscal) is not a regulated title. Giving legal advice on a regular basis and for payment, on the other hand, is reserved: Article 54 of Law No. 71-1130 of 31 December 1971 prohibits it for anyone who does not meet the competence requirements it sets. Regulated professions, such as chartered accountants, may give advice relating to their main activity, within the limits set by Article 59 of the same law.

Professional	Main role in tax matters	When to consult them
Chartered accountant (expert-comptable)	Keeping and presenting the accounts, the company’s routine tax returns	Recurring tax compliance
Notary (notaire)	Authentic instruments; gifts between living persons are executed before a notary (Article 931 of the French Civil Code)	Gift, inheritance, property sale
Tax lawyer (avocat fiscaliste)	Advice, drafting, defence in tax audits, litigation and criminal proceedings, under professional secrecy	High-stakes transaction, tax audit, dispute, criminal complaint

These professionals work together. We act alongside your chartered accountant and your notary, without replacing them: each keeps their own role, and your file gains in consistency.

Assisting you in a French tax audit

The tax authorities have several audit tools, governed by the French Tax Procedure Code (Livre des procédures fiscales (in French), LPF): requests for information, the right of disclosure (Articles L. 81 et seq. LPF), desk audits and on-site audits of the accounts (Articles L. 10 and L. 13 LPF), and the in-depth review of an individual’s overall tax position (Article L. 12 LPF). Each procedure follows precise rules and formalities that give the taxpayer rights.

As soon as you receive a notice of tax audit (avis de vérification), we step in to frame communications with the audit department, prepare the responses, request the adversarial meetings provided for by the Charter of the Audited Taxpayer (Charte du contribuable vérifié), and ensure that procedural safeguards are respected (reasonable time, assistance from an adviser, limited duration of on-site audits for small businesses within the meaning of Article L. 52 LPF).

At the end of the audit, the tax authorities notify their position in a reasoned proposed tax reassessment (proposition de rectification, Article L. 55 LPF). You then have thirty days from receipt to respond (Article R*57-1 LPF), a period that may be extended under the conditions of Article L. 57 LPF. This response is decisive: it crystallises your defence and determines whether later arguments will be admissible. We draft it with supporting documents and references to administrative guidance and case law.

Where reassessments are upheld, the French Tax Code (Code général des impôts (in French), CGI) provides for penalties: late-payment interest (Article 1727 CGI), a 40% penalty for deliberate failure and 80% for fraudulent practices or abuse of law (Article 1729 CGI). We systematically challenge penalties where the tax authorities have not established their constituent elements.

Tax audits and disputes: who does what, and by when

This table summarises the stages of a tax audit and of any dispute that may follow. Time limits run from receipt of each document: keep the envelopes and acknowledgements of receipt.

Stage	What the law provides	Reference	The lawyer’s role
Notice of tax audit	Must state, on pain of nullity, that you may be assisted by an adviser; the Charter of the Audited Taxpayer is available online	Art. L. 47 LPF	Check the notice, prepare the first intervention
Charter of the Audited Taxpayer	Its provisions are binding on the tax authorities	Art. L. 10 LPF	Invoke the safeguards of the Charter
On-site audit of a small business	Three months at most, save for the exceptions provided by law	Art. L. 52 LPF	Check that the time limit is respected
Proposed tax reassessment	Reasoned; thirty days to respond, extendable under the conditions of Article L. 57	Art. L. 57 and R*57-1 LPF	Draft the observations
Reply to your observations	Any rejection of your observations must be reasoned	Art. L. 57 LPF	Analyse the reasoning
Appeal to the superior, then to the interlocuteur	Request to be made within thirty days of the reply to your observations	BOI-CF-PGR-20-10	Refer the matter to the auditor’s superior, then to the interlocuteur
Departmental commission	Competent in particular on the amount of profits and market value; it does not decide questions of law	Art. L. 59 A LPF	Prepare and present the file
Regularisation during the audit	Late-payment interest reduced to 70%, subject to conditions	Art. L. 62 LPF	Assess whether it is advisable
Prior administrative claim	Mandatory before any court action; as a general rule, until 31 December of the second year following the date the tax was put into collection	Art. R*190-1 and R*196-1 LPF	Draft and follow up the claim
Court action	Administrative court for direct taxes and turnover taxes; civil court (tribunal judiciaire) for registration duties and IFI	Art. L. 199 LPF	Bring the case before the competent court

The full course of a tax audit is set out on our tax audit lawyer page.

The tax procedures we handle

Each procedure has its own time limits and safeguards. The pages below cover them one by one.

• Request for information: how to respond;
• Desk audit and remote audit of the accounts (in French);
• On-site audit of the accounts (in French) at the company’s premises;
• In-depth review of an individual’s overall tax position (Article L. 12 LPF): our tax audit lawyer page;
• Proposed tax reassessment and response within thirty days;
• Default assessment (taxation d’office): if no return is filed within the legal time limit, the tax authorities may assess you ex officio (Article L. 66 LPF). For income tax and registration duties, they must first send you a formal notice, which gives you thirty days to regularise (Article L. 67 LPF);
• Appeal to the superior (recours hiérarchique), then to the interlocuteur;
• Direct Taxes and Turnover Taxes Commission (in French);
• Abuse of Tax Law Committee;
• Challenging a third-party administrative garnishment (in French) (saisie administrative à tiers détenteur), within two months of its notification;
• Prior tax claim (in French), then application to the administrative court, appeal and appeal on points of law to the Conseil d’État (in French).

Defending your interests in tax litigation and criminal proceedings

The litigation phase opens with a prior claim to the tax authorities (Articles L. 190 and R*196-1 LPF). If it is rejected, the case can be brought before the competent court: the administrative court (tribunal administratif) for the basis of assessment and collection of direct taxes and turnover taxes, the civil court (tribunal judiciaire) for registration duties and real estate wealth tax. Tax litigation (in French) is a highly formal area, where every time limit counts.

Criminal proceedings begin when the tax authorities file a complaint for tax fraud under Article 1741 of the French Tax Code. This offence is punishable by five years’ imprisonment and a €500,000 fine, an amount that may be increased to twice the proceeds of the offence. Since the Law of 23 October 2018, the “Bercy lock” (verrou de Bercy) has been relaxed: Article L. 228 LPF requires the tax authorities to refer the facts to the public prosecutor where the tax due exceeds €100,000 and carries a 100% or 80% penalty, or a 40% penalty in the case of repeat conduct within the previous six years.

Our team handles criminal tax defence before the criminal court (tribunal correctionnel), the criminal division of the court of appeal and, where applicable, the National Financial Prosecutor’s Office (PNF). We coordinate the tax and criminal strategy, examine procedural defects and, where relevant, negotiate a guilty-plea procedure (comparution sur reconnaissance préalable de culpabilité) or, for legal entities, a judicial public interest agreement (convention judiciaire d’intérêt public).

How far back can the French tax authorities audit?

For income tax and corporate income tax, the tax authorities can make reassessments until the end of the third year following the year for which the tax is due (Article L. 169 LPF). For tax due for 2023, this period therefore expires on 31 December 2026.

The same article extends this period to ten years in several cases: undisclosed activity, fictitious domicile abroad or failure to meet certain reporting obligations, in particular for accounts held abroad. On the criminal side, the tax authorities may file a complaint for tax fraud until the end of the sixth year following the year of the offence (Article L. 230 LPF). All the time limits are brought together in our article on the tax limitation period.

Regularising your position, before or during a tax audit

An error discovered before any audit is corrected by an amended return. Filed voluntarily, under the conditions of Article 1727 V of the CGI, it reduces late-payment interest by 50%. This interest runs at 0.20% per month (Article 1727 III of the CGI).

During an audit, you can still ask to regularise certain errors, subject to conditions: late-payment interest is then reduced to 70% of its amount (Article L. 62 LPF). The 40% or 80% penalties for deliberate failure, abuse of law or fraudulent practices fall under a different regime (Article 1729 of the CGI).

The choice of approach and its timing are decided case by case. See our tax regularisation page.

Accounts, policies and assets held abroad

If you are domiciled in France, you declare each year, with your income, the details of accounts opened, held, used or closed abroad (Article 1649 A of the CGI). Sums transferred through an undeclared account are deemed, unless proven otherwise, to be taxable income.

An oversight is costly. The fine is €1,500 per undeclared account. It rises to €10,000 where the account is in a State or territory that has not concluded an administrative assistance agreement with France giving access to banking information (Article 1736 of the CGI). In the event of a reassessment, an 80% penalty applies to the tax due on the sums concerned (Article 1729-0 A of the CGI), and the reassessment period becomes ten years, unless the total credit balances of your foreign accounts did not exceed €50,000 during the year (Article L. 169 LPF).

An old account, an inheritance received abroad, a life insurance policy taken out outside France: regularisation should be prepared before the tax authorities question you. See our tax regularisation and tax and expatriation pages, and our article on the national register of bank accounts (FICOBA) (in French). Penalties, time limits and the regularisation process are detailed on our undeclared foreign bank accounts page.

Structuring and securing your wealth transactions

Structuring your wealth or an investment starts with a preliminary review: assets, liabilities, cash flows, holding horizon, succession objectives. We act ahead of sensitive transactions – sale of a business, contribution and sale, gift, transfer under a pact, expatriation – to identify the most coherent structure in light of the law and your objectives.

Among the legal mechanisms frequently used, the contribution and sale scheme (apport-cession) under Article 150-0 B ter of the CGI allows, subject to conditions, the tax on the capital gain arising on the contribution to be deferred. Where the receiving company sells the contributed shares within three years, the deferral is maintained if it reinvests at least 70% of the sale proceeds, within three years, in an eligible activity. The assets or shares acquired must be held for at least five years. These rules apply to disposals made since 21 February 2026: see our article on contribution and sale in 2026 (in French).

The Dutreil pact (Article 787 B of the CGI) exempts shares passed on under a holding commitment from gift and inheritance duties on 75% of their value. It requires a collective commitment of at least two years, followed by an individual commitment of six years by each heir or donee. Since 21 February 2026, certain assets not used exclusively for the business are excluded from the exemption, such as residential property, passenger vehicles or works of art. The details are in our article on the Dutreil pact in 2026 (in French). To pass on shares before selling them, see our article on gifting shares before a sale (in French); for split ownership for a fixed term, see our article on the sale of a temporary usufruct (in French).

To secure a structure, the advance tax ruling (rescrit fiscal) under Article L. 80 B of the Tax Procedure Code remains the most protective tool. Properly drafted, it binds the tax authorities and protects the taxpayer from a later challenge, provided that the facts set out accurately reflect the actual situation. We prepare, follow through and defend ruling requests for the most sensitive transactions.

Real estate taxation in France: buying, holding, passing on, selling

Real estate attracts several taxes: registration duties on purchase, property income while you hold it, real estate wealth tax, capital gains tax on resale, transfer duties on succession or gift. The way you hold the property (directly, through an SCI (non-trading property company), or with split ownership) should be chosen before purchase, as it is difficult to undo afterwards.

For an individual, the capital gain on the sale of a property is taxable (Article 150 U of the CGI), unless an exemption applies. The main exemption covers the seller’s main residence on the day of the sale. For income tax purposes, the gross gain is reduced by 6% per year of ownership beyond the fifth, then by 4% for the twenty-second year (Article 150 VC of the CGI): it is therefore exempt from income tax after twenty-two years of ownership.

Real estate wealth tax applies to persons whose real estate assets exceed €1,300,000 (Article 964 of the CGI). We advise on structuring ownership, the sale of SCI shares, split ownership, what happens to a property kept in France after moving abroad, and defence in tax audits concerning the declared value of a property. See our real estate tax lawyer and IFI lawyer pages.

How our firm assists you

Our tax practice works closely with our corporate practice. This allows us to handle, in a single file, the tax aspects of a merger or acquisition, a sale of a business (fonds de commerce), a group restructuring or insolvency proceedings. We also work in coordination with the chartered accountants, notaries and wealth management advisers already in place.

Our method has three stages: an initial scoping meeting to identify the issues and set the scope, an analysis and drafting phase documented by legislation and administrative guidance, then an execution or litigation phase. Each stage results in written deliverables.

To present your case and explore the options together, please get in touch via the firm’s contact form. An initial discussion makes it possible to assess the situation and the next steps.

Our tax law firm in Paris 8e

The firm sees clients by appointment at 51 avenue Franklin Delano Roosevelt, in the 8th arrondissement of Paris. We act for individuals and businesses in Paris, whether you are in the 8th, 16th or 17th arrondissement, in the Île-de-France region or elsewhere in France: exchanges with the tax authorities are largely in writing, so a file can be handled wherever you live. For an initial discussion, use our contact form.

Tax lawyer fees in Paris: how they are set

Fees are agreed with you. Except in cases of urgency, force majeure or legal aid, the lawyer enters into a written fee agreement with the client, which specifies the amount or the method of calculation (Article 10 of Law No. 71-1130 of 31 December 1971).

The law sets several criteria: your financial situation, the difficulty of the matter, the costs incurred, the lawyer’s reputation and the work carried out. Depending on the engagement, we offer a fixed fee (advance tax ruling, amended return, response to a proposed reassessment) or an hourly rate (tax audit, litigation). A fee based solely on the outcome of court proceedings is prohibited; an additional success fee may be added to the fee for the work carried out.

The initial discussion helps us understand your case before any fee proposal. Our ways of working are also presented on our fees page. Billing methods are detailed on the tax lawyer fees page.

Frequently asked questions

What does a tax lawyer do in France?

A tax lawyer advises, drafts and argues cases on all tax matters. They secure transactions in advance (sale, contribution of assets, gift, expatriation, restructuring), defend you in a tax audit, file the claim and then bring the case before the competent court and, if necessary, conduct the criminal defence when a complaint for tax fraud is filed.

When should you call on a tax lawyer?

As soon as a transaction involves a sensitive tax issue: selling a business, passing on wealth, a substantial gift, moving abroad, receiving a notice of tax audit, a request for information from the tax authorities, being placed under formal investigation (mise en examen) for tax fraud. The earlier the intervention, the wider the room for manoeuvre.

How do you choose a tax lawyer?

Check admission to the Bar, any specialisation in tax law, experience in both advisory and litigation work, and the firm’s ability to handle both the tax and the corporate aspects of a transaction. The quality of the working relationship and the clarity of the deliverables matter as much as technical skill.

What are the limitation periods in French tax matters?

For income tax and corporate income tax, the tax authorities can make reassessments until the end of the third year following the year for which the tax is due (Article L. 169 LPF). This period rises to ten years in certain cases, in particular for undisclosed activity or undeclared accounts held abroad. A complaint for tax fraud may be filed until the end of the sixth year following the year of the offence (Article L. 230 LPF).

What is the difference between a tax reassessment and tax fraud?

A reassessment is the administrative procedure that results in the tax due being recalculated, together with civil penalties where applicable. Tax fraud is a criminal offence punishable under Article 1741 of the French Tax Code, which requires an intentional element (deliberate omission, concealment of sums, fraudulent practices). The two procedures may be combined, subject to the principle of proportionality laid down by the French Constitutional Council.

Does professional secrecy apply to exchanges with a tax lawyer?

Yes. The lawyer’s professional secrecy, established by Article 66-5 of Law No. 71-1130 of 31 December 1971, covers all legal consultations, correspondence and documents exchanged in the course of the engagement. It is general, absolute and a matter of public policy, which makes it an essential tool in tax matters.

What are the penalties for proven tax fraud?

Article 1741 of the French Tax Code provides for up to five years’ imprisonment and a €500,000 fine, which may be increased to twice the proceeds of the offence. Penalties are heavier where aggravating circumstances apply (organised gang, accounts abroad, fictitious domicile), with maximums raised to seven years and three million euros. Additional penalties (ineligibility, ban on practising) may be imposed.

Can you regularise your tax position without waiting for an audit?

Yes. An amended return filed voluntarily, before any audit, reduces late-payment interest by 50%, under the conditions of Article 1727 V of the CGI. During an audit, Article L. 62 LPF still allows certain errors to be regularised, with late-payment interest reduced to 70%. We prepare the amended returns and liaise with the competent tax office.

How much does a tax lawyer in Paris cost?

Fees are agreed with you in a written agreement, except in urgent cases. The law takes into account your financial situation, the difficulty of the case, the costs incurred, and the lawyer’s reputation and work. We offer a fixed fee or an hourly rate depending on the engagement. A fee based solely on the outcome of court proceedings is prohibited (Article 10 of Law No. 71-1130).

How long do you have to respond to a proposed tax reassessment?

You have thirty days from receipt (Article R*57-1 LPF). This period may be extended under the conditions of Article L. 57 LPF. The proposal must be reasoned, so that you can make your observations.

What if you still disagree after the tax authorities’ reply?

You can refer the matter to the auditor’s superior, then to the interlocuteur appointed by the director, within thirty days (BOI-CF-PGR-20-10). On certain questions of fact, such as the amount of profits or the market value of an asset, the matter can also be referred to the departmental commission (Article L. 59 A LPF).

Can you obtain the tax authorities’ position before a transaction?

Yes, through a ruling request (rescrit). When a taxpayer acting in good faith submits a written, precise and complete request, the tax authorities give their position within three months. Their formal position is then binding on them under the conditions of Article L. 80 B LPF.

How long do you have to challenge a tax in France?

The claim is first sent to the competent tax office (Article R*190-1 LPF). As a general rule, it is admissible until 31 December of the second year following the date the tax was put into collection or the event giving rise to the claim (Article R*196-1 LPF). Only then can the case go to court, depending on the tax concerned.

What is the difference between a tax lawyer and a tax adviser?

“Tax adviser” is not a protected title in France. A lawyer is admitted to the Bar, bound by professional secrecy and can represent you before the tax authorities and the courts. Paid legal advice is reserved for professionals who meet the conditions of Article 54 of Law No. 71-1130 of 31 December 1971.

Do you have to declare a bank account held abroad?

Yes. Individuals domiciled in France declare, with their income, the accounts opened, held, used or closed abroad (Article 1649 A of the CGI). Failing this, the fine is €1,500 per account, rising to €10,000 for an account located in a State or territory without an administrative assistance agreement with France (Article 1736 of the CGI).

Does a tax lawyer handle real estate taxation?

Yes: choosing how to hold the property (directly, through an SCI, with split ownership), capital gains, real estate wealth tax, transfer and defence in tax audits. The notary remains competent for authentic instruments, such as gifts (Article 931 of the French Civil Code).

Official sources

• Article L. 169 of the French Tax Procedure Code (reassessment period): Légifrance (in French)
• Articles L. 57 and R*57-1 of the French Tax Procedure Code (proposed reassessment): Légifrance (in French)
• Article L. 62 of the French Tax Procedure Code (regularisation during an audit): Légifrance (in French)
• Article 1727 of the French Tax Code (late-payment interest): Légifrance (in French)
• Article 1741 of the French Tax Code (tax fraud): Légifrance (in French)
• Article L. 228 of the French Tax Procedure Code (referral to the public prosecutor): Légifrance (in French)
• Article 150-0 B ter of the French Tax Code (contribution and sale): Légifrance (in French)
• Article 787 B of the French Tax Code (Dutreil pact): Légifrance (in French)
• BOI-CF-PGR-20-10 (appeal to the superior and interlocuteur): BOFiP-Impôts (in French)
• Article 10 of Law No. 71-1130 of 31 December 1971 (fees): Légifrance (in French)
• Article 54 of Law No. 71-1130 of 31 December 1971 (legal advice): Légifrance (in French)
• Article 59 of Law No. 71-1130 of 31 December 1971 (regulated professions): Légifrance (in French)
• Article 931 of the French Civil Code (form of gifts): Légifrance (in French)
• Article 1649 A of the French Tax Code (accounts held abroad): Légifrance (in French)
• Article 1736 of the French Tax Code (fine for an undeclared account): Légifrance (in French)
• Article 1729-0 A of the French Tax Code (80% penalty): Légifrance (in French)
• Article 150 U of the French Tax Code (capital gains on real estate): Légifrance (in French)
• Article 150 VC of the French Tax Code (holding-period allowance): Légifrance (in French)
• Article 964 of the French Tax Code (real estate wealth tax): Légifrance (in French)
• Article L. 66 of the French Tax Procedure Code (default assessment): Légifrance (in French)
• Article L. 67 of the French Tax Procedure Code (formal notice): Légifrance (in French)

Law as in force on 1 October 2026. Page written under the responsibility of Maître Harry Allouche. This content provides general information and does not constitute legal advice. Every situation is different: the firm commits to the means it deploys, without any promise of outcome.