The tax statute of limitations sets the period during which the French tax authorities can correct a tax. It is also called the statute of limitations for tax reassessment (délai de reprise). Once this period has expired, an error or omission can no longer be corrected. Its length varies, from three to ten years, according to the tax concerned and the taxpayer’s conduct.
Knowing how many years a tax audit can cover lets you measure your real exposure. This article sets out the main periods laid down in the French Tax Procedure Code (Livre des procédures fiscales, LPF). It does not replace an individual analysis: every situation is different.
French tax audit: how many years back?
The table below summarises the most common reassessment periods. Each is detailed later in the article.
| Tax or situation | Period | The period runs until the end of | Text |
|---|---|---|---|
| Income tax and corporate income tax, general case | 3 years | the 3rd year following the year for which the tax is due | LPF, Art. L. 169 |
| Income tax and corporate income tax: undeclared business activity, sham tax domicile abroad, undeclared foreign assets | 10 years | the 10th year following the year for which the tax is due | LPF, Art. L. 169 |
| VAT | 3 years | the 3rd year following the year in which the tax became chargeable | LPF, Art. L. 176 |
| Registration duties and IFI, chargeability sufficiently disclosed | 3 years | the 3rd year following the year of registration or assessment | LPF, Art. L. 180 |
| Where no special period applies | 6 years | the 6th year following the year of the taxable event | LPF, Art. L. 186 |
| Criminal complaint for tax fraud | 6 years | the 6th year following the year of the offence | LPF, Art. L. 230 |
The general rule: three years
Income tax and corporate income tax
Article L. 169 of the LPF sets the principle. The tax authorities can reassess income tax and corporate income tax within a limited period. This period runs until the end of the third year following the year for which the tax is due. The count is therefore made in full calendar years.
Take a simple example. For tax due for 2023, the tax authorities can act until 31 December 2026. On 1 January 2027, the year 2023 is in principle time-barred. The exceptions described below may, however, extend this period.
VAT: a period calculated from chargeability
For VAT, Article L. 176 uses a different starting point. The tax authorities can act until the end of the third year following the year in which the tax became chargeable. The period therefore follows the date on which the tax became chargeable. A business must thus keep two separate calendars: one for corporate income tax and one for VAT.
When does the reassessment period extend to ten years?
The same Article L. 169 extends the reassessment period to ten years in several situations. The period then runs until the end of the tenth year following the year for which the tax is due. The situations covered are:
- carrying on an undeclared business activity;
- a sham tax domicile abroad;
- failure to report accounts opened, held, used or closed abroad (Article 1649 A of the French Tax Code, CGI);
- failure to comply with the obligations relating to capitalisation contracts taken out abroad (1649 AA), trusts (1649 AB) and crypto-assets (1649 bis C);
- failure to comply with the obligations laid down in Articles 123 bis and 209 B of the CGI.
The exception for small foreign accounts
For undeclared foreign accounts, the extension to ten years is not automatic. It does not apply if the taxpayer proves a specific condition. The total credit balances of their foreign accounts must not, at any time during the year, have exceeded €50,000. The burden of proof is on you: keep your foreign bank statements.
This exception does not remove the reporting obligation. Article 1736 of the CGI provides for a fine of €1,500 per unreported account. It rises to €10,000 per account where the State concerned has not concluded with France an administrative assistance agreement giving access to banking information.
Registration duties, gifts and IFI: three or six years
Duties due on a gift fall under registration duties, governed by Article L. 180 of the LPF. The tax authorities can reassess them until the end of the third year following the year of registration. This three-year period is subject to one condition: the registered deed must have sufficiently disclosed that the duties were chargeable.
Failing that, a longer period applies. Article L. 186 provides for a six-year reassessment period where no special period applies. It runs until the end of the sixth year following the year of the taxable event. This is the rule people refer to when they speak of a six-year tax statute of limitations for a gift.
The drafting of the deed of gift, executed before a notary under Article 931 of the French Civil Code (Code civil), therefore matters a great deal. An omission in the deed can move the file from the three-year period to the six-year period. If you are planning to pass on assets, our article on whether to make a gift before 2027 (in French) reviews the timetable.
The case of IFI
The IFI (French real estate wealth tax) follows a similar logic. The three-year period of Article L. 180 applies if the taxpayer has complied with the return provided for in Article 982 of the CGI. Failing that, the six-year period of Article L. 186 may apply. Moreover, a taxpayer who does not state the net taxable value in their income tax return is exposed to a default assessment (taxation d’office) (Article L. 66, 4°).
What interrupts the statute of limitations?
The reassessment period is not always fixed. Under Article L. 189 of the LPF (in French), the statute of limitations is interrupted in particular by notification of a proposed tax reassessment (proposition de rectification), by the declaration or notification of an official report (procès-verbal) and by any act involving an acknowledgement by the taxpayer. For a default assessment, Article L. 76 of the LPF provides that notification of the bases and terms of assessment interrupts the statute of limitations; it must take place at least thirty days before the tax is put into collection.
Checking the date of each notification against the applicable period is therefore a basic precaution. Keep the envelopes and the acknowledgements of receipt. If a tax reassessment is notified to you, our article on the possible consequences of a tax reassessment (in French) details what to expect next. Assistance from a tax audit lawyer makes it possible to check these dates from the start of the procedure.
Tax fraud: six years to file a complaint
The reassessment period for tax must not be confused with the limitation period for criminal proceedings. Under Article L. 230 of the LPF, a criminal complaint for tax fraud may be filed until the end of the sixth year following the year of the offence. This period concerns criminal prosecution, which is separate from the tax reassessment.
The same situation may therefore expose you to a tax reassessment and to criminal proceedings, each with its own timetable. Our page on tax fraud defence describes how we assist.
Key points
- The reassessment period is in principle three years for income tax, corporate income tax and VAT.
- It rises to ten years in the event of undeclared business activity, a sham tax domicile abroad or undeclared foreign assets.
- For a gift, the period is three years if the deed sufficiently discloses that the duties are chargeable, and six years otherwise.
- In a default assessment, notification of the bases interrupts the statute of limitations (Article L. 76 of the LPF).
- A criminal complaint for tax fraud may be filed until the end of the sixth year following the offence.
To check the periods that apply to your file, you can consult a tax lawyer in Paris at our firm. The tax team, headed by Harry Allouche (Maître), assists you during a tax audit as well as before a transfer of assets.
FAQ
How long is the tax statute of limitations in France?
The standard reassessment period is three years for income tax and corporate income tax (Article L. 169 of the French Tax Procedure Code). It runs until the end of the third year following the year for which the tax is due. It can reach ten years in certain situations.
Can a French tax audit go back ten years?
Yes, in the cases provided for by Article L. 169 of the French Tax Procedure Code: undeclared business activity, sham tax domicile abroad, or failure to report accounts, capitalisation contracts, trusts or crypto-assets abroad. For foreign accounts, the extension does not apply if the taxpayer proves that the total credit balances never exceeded €50,000 during the year.
When does the six-year tax statute of limitations apply?
Article L. 186 of the French Tax Procedure Code provides for a six-year period where no special period applies, until the end of the sixth year following the year of the taxable event. It applies in particular where the conditions for the three-year period of Article L. 180 are not met, for example if the deed did not sufficiently disclose that the duties were chargeable.
What is the statute of limitations for a gift?
Duties due on a gift may be reassessed until the end of the third year following the year of registration, if the deed sufficiently disclosed that they were chargeable (Article L. 180 of the French Tax Procedure Code). Failing that, the six-year period of Article L. 186 applies.
Can the statute of limitations be interrupted?
Yes. Article L. 76 of the French Tax Procedure Code provides that notification of the bases and terms of a default assessment interrupts the statute of limitations. This notification takes place at least thirty days before the tax is put into collection.
Official sources
- Article L. 169 of the French Tax Procedure Code (reassessment period for income tax and corporate income tax): Légifrance (in French)
- Article L. 176 of the French Tax Procedure Code (reassessment period for VAT): Légifrance (in French)
- Article L. 180 of the French Tax Procedure Code (registration duties and IFI): Légifrance (in French)
- Article L. 186 of the French Tax Procedure Code (standard six-year reassessment period): Légifrance (in French)
- Article L. 76 of the French Tax Procedure Code (notification interrupting the statute of limitations): Légifrance (in French)
- Article L. 230 of the French Tax Procedure Code (limitation period for tax fraud complaints): Légifrance (in French)
Law verified as at 5 October 2026. Content written under the responsibility of Harry Allouche (Maître). This content provides general information and is not legal advice. Every situation is different: the firm commits to the means it deploys, with no promise of outcome.
