#Voluntary Tax Disclosure Lawyer in France

Voluntary tax disclosure (régularisation fiscale) is the process by which a taxpayer spontaneously reveals to the tax authorities items they had not declared and pays the corresponding taxes, together with late-payment interest and, where applicable, penalties. It covers complex situations, such as holding undeclared accounts or assets abroad, as well as more one-off omissions concerning income or wealth that was not fully declared.

The decision to regularise should not be taken lightly. It requires a precise analysis of the situation, an assessment of the amounts at stake and of the applicable penalties, and a strategy defined together with a tax lawyer. A poorly prepared regularisation may leave omissions in place or expose you to additional assessments that have been poorly calculated.

Undeclared accounts and income: situations that call for regularisation

The most frequent situations concern holding undeclared bank accounts abroad, receiving undeclared foreign income (dividends, rents, capital gains), holding undeclared foreign structures (companies, trusts, foundations), omissions in inheritance or gift tax returns, or repeated errors in annual tax returns.

Why regularise rather than wait

The tax authorities have growing access to information on assets held abroad, in particular through the automatic exchanges of information between States in place since 2017. A taxpayer whose situation is known, or likely to be identified through these mechanisms, has an interest in regularising spontaneously rather than waiting for an audit. Spontaneous regularisation generally makes it possible to obtain more favourable terms on penalties than regularisation forced by an audit.

The voluntary disclosure process

Well-managed regularisation involves several steps: a complete analysis of the tax position, identification of the years concerned and the amounts at stake, preparation of the amended returns, calculation of the taxes, interest and penalties due, and organisation of the dialogue with the tax authorities.

We assist taxpayers in this process, ensuring that the procedure is legally sound and optimising the terms of the regularisation within the applicable legal framework.

Criminal risks

Tax fraud is a criminal offence under French law. Depending on the seriousness of the situation and the amounts at stake, regularisation may require anticipating criminal risks and dealing with them together with the tax aspects. We assess these risks from the initial analysis and adapt our strategy accordingly.

See also our dedicated tax fraud lawyer page.

When to consult us

As soon as you identify a potentially irregular situation, and before any spontaneous contact with the tax authorities. When you receive a request for information from the tax authorities about assets or income abroad. When you wish to assess your tax exposure and the options available.

Official sources

• Article 1727 of the French Tax Code (Code général des impôts) (in French): late-payment interest, reduced by 50% in the event of a spontaneous amended return.
• Council Directive 2014/107/EU of 9 December 2014: automatic exchange of information on financial accounts between tax authorities.

Every situation is different: the information on this page is general and does not replace legal advice tailored to your case. The firm makes no promise of outcome; it commits to the means it deploys.