←ExpertiseCompliance and disputes

Tax audits and proposed reassessments

Protecting your interests. Preserving your peace of mind.

A proposed reassessment opens a thirty-day period to reply, extended by thirty days on a request made before it expires. For income tax, the authorities can in principle reassess until the end of the third year following the tax year, and up to ten years in some cases. The firm acts from the notice of audit or the proposed reassessment through to litigation.

Cassandre Nogues, tax lawyerPublished 23 September 2026Updated 9 October 2026

A tax audit calls for an immediate grasp of what is at stake and a strategy suited to your personal and wealth situation.

We assist, in strict confidence, directors, entrepreneurs, investors and families in high-stakes tax audits, in France and abroad.

Our support

How does the firm assist, from the first letter to the hearing?

01
Reviewing the audit and the risks
Identifying the procedure under way (desk audit, personal tax position review, accounts audit), examining the documents already filed and mapping the points that call for an answer.
02
Setting the strategy
Sorting the positions that can be defended from the points to be regularised, planning the timetable for each reply and choosing the procedural safeguards to invoke.
03
Handling exchanges with the tax authorities
Drafting replies to requests for information and evidence, preparing the meetings and attending the oral exchanges with the inspector.
04
Challenging reassessments and penalties
Replying to the reassessment proposal, referring the file to the inspector’s superior and to the departmental representative, bringing the matter before the relevant commissions, and contesting the surcharges and their grounds.
05
Settlement and litigation
Applications for settlement and for remission of penalties, formal claims, then representation before the administrative or civil courts depending on the tax at stake.

Where we act

Which audits does the firm handle?

Tax residence and global mobility

Challenges to tax residence, application of double tax treaties, exit tax and the conditions of the inbound (impatriate) regime.

Foreign income and assets

Income from foreign sources, treaty tax credits and the treatment of portfolios and property held outside France.

Accounts, trusts and foreign structures

Undeclared accounts and life insurance policies, trust reporting duties, foreign companies and article 123 bis of the French Tax Code, together with the related fines.

Disposals and wealth transactions

Capital gains on disposals, contribution-disposals and the reinvestment condition, management packages and challenges to preferential regimes.

Real estate wealth tax (IFI)

Valuation of the properties, deductibility of the liabilities and the perimeter of shares in property-rich companies.

Gifts and succession

Valuation of the assets passed on, Dutreil pact undertakings, undeclared gifts and the presumptions of article 751 of the French Tax Code.

Case studies

→Challenging an IFI reassessment →Regularising undeclared foreign accounts →Regularising crypto-asset wallets held abroad

What are the deadlines in a tax audit?

Deadlines in force in 2026
Deadline	Duration in 2026	Source
Reassessment period, income tax and corporate tax	until 31 December of the third year following the tax year	BOFiP, BOI-CF-PGR-10-20
Undeclared activity	ten years	BOFiP, BOI-CF-PGR-10-70
Undeclared foreign accounts, life insurance contracts or trusts	ten years (accounts: unless total balances did not exceed €50,000 at any time during the year)	BOFiP, BOI-CF-PGR-10-50
Reply to a proposed reassessment	thirty days, plus thirty days on request	BOFiP, BOI-CF-IOR-10-50-10
On-site audit of a small business	three months	BOFiP, BOI-CF-PGR-20-30
Taxpayer’s claim	until 31 December of the second year following assessment	BOFiP, BOI-CTX-PREA-10-30
Claim after a reassessment procedure	same period as the tax authorities	BOFiP, BOI-CTX-PREA-10-40