Tax Audit and Litigation Lawyer in Toulouse

Facing a tax audit with proper preparation

The firm assists businesses and individuals from the receipt of an audit notice through to litigation before the tax courts. Each stage of the procedure is anticipated with the lawyer.

Schedule an Appointment

Strategic Support Against the Tax Authorities

Facing a tax audit or a tax adjustment is often a source of concern for both businesses and individuals. The financial stakes can be considerable, and procedural errors can have serious consequences. The firm VV Avocat, tax lawyer in Toulouse, intervenes from the initial stages to assist you, secure your responses, and defend your interests against the tax authorities.

Our work is to anticipate the tax authority's demands, prepare the arguments and avoid procedural errors that often weigh heavily in the final outcome. Every exchange with the auditor is prepared with you in advance.

As a tax audit and tax litigation lawyer in Toulouse, the firm steps in at every stage: receipt of a notice of audit, accounting audit of a business, review of an individual’s personal tax situation, reply to a proposed reassessment, appeal to the auditor’s superiors, the departmental tax commission, formal tax claim and proceedings before the administrative court. The seven situations below explain, for each one, what happens, which time limits apply and what the firm actually does.

French Tax Audits: Seven Situations, Your Deadlines and the Firm’s Role

A tax audit is the procedure through which the French tax authorities check that the returns you filed are accurate. It takes one of two forms: a desk audit, carried out from the tax office on the basis of your returns, or an on-site or remote audit, which for a business means a full tax audit or a remote review of its accounting files, and for an individual a review of their overall personal tax position (examen de situation fiscale personnelle, ESFP).

A French tax audit is a written procedure, and most time limits start running when you receive a registered letter. The guidance below reflects the rules in force in October 2026, as set out in the French Tax Procedure Code (Livre des procédures fiscales, LPF) and the official tax guidance (BOFiP). Every case still needs to be checked on its own facts.

You receive a notice of audit

The tax authority announces either an accounting audit (for a business) or a review of your personal tax situation (for an individual). The notice of audit (avis de vérification) must state the years under review and your right to be assisted by an adviser of your choice (article L. 47 LPF), and you must be given enough time before the first on-site visit.

  • What you are asked to do: keep your accounts and supporting documents available on the date set.
  • What the firm does: checks that the notice is valid, asks for a reasoned postponement if needed, prepares the first meeting.
  • Next step: read our guide French tax audit notice: what to do upon receipt.

An accounting audit of your business

The auditor reviews your books, invoices, contracts and accounting entries files on site. For businesses whose turnover does not exceed the thresholds of the simplified tax regime, the on-site audit cannot last more than three months (article L. 52 LPF). You are entitled to a genuine face-to-face discussion with the auditor (débat oral et contradictoire): this safeguard must be respected.

  • Useful documents: general ledger, journals, purchase and sales invoices, bank statements, contracts, minutes of shareholders’ meetings.
  • What the firm does: frames the auditor’s requests, prepares written answers, attends the meetings, keeps track of the length and regularity of the procedure.
  • Next step: a closing meeting, then a proposed reassessment or a notice that no reassessment will be made.

A tax audit of an individual (ESFP)

The review of an individual’s personal tax situation (examen contradictoire de la situation fiscale personnelle, ESFP) tests whether your declared income is consistent with your assets and lifestyle. As a rule, it cannot run for more than one year from receipt of the notice (article L. 12 LPF). The tax authority may also use content made public online to select taxpayers for audit: see how the French tax authority investigates online.

  • What you are asked for: bank statements, evidence for large transactions, the source of funds and, where relevant, accounts and contracts held abroad.
  • What the firm does: rebuilds and documents your cash flows, answers requests for clarification and justification, protects you against an ex officio assessment.
  • Next step: a proposed reassessment, or closure with no additional tax.

You receive a proposed reassessment

This is the document in which the tax authority sets out the additional tax it intends to charge and its reasons. You have thirty days from receipt to submit your observations, extended by thirty days if your request reaches the tax authority before the deadline expires (articles L. 57 and R. 57-1 LPF).

  • What to do: ask for the extension as soon as the letter arrives if the file is large, gather your documents, do not miss the deadline.
  • What the firm does: reviews the grounds and the procedure (formal defects, statute of limitations, burden of proof), puts figures on what is at stake, sets the reply strategy.
  • Next step: see how to respond to a proposed tax reassessment.

A reasoned reply to the proposed reassessment

Your written observations set the terms of the discussion with the tax authority and shape the rest of the case. The reply must be grounded in law (statutes, official guidance published in the BOFiP, case law) and backed by figures.

  • Useful documents: any evidence showing that expenses were genuine, where money came from or what an asset was worth.
  • What the firm does: drafts the observations, requests a meeting with the auditor, negotiates the factual points.
  • Next step: the tax authority replies to your observations, maintaining, reducing or dropping the adjustments.

Challenging the outcome: appeal to superiors and the tax commission

If you still disagree, two out-of-court routes come before any lawsuit. The first is an appeal to the auditor’s superior, then to the departmental liaison officer (interlocuteur départemental), a safeguard set out in the charter of rights and obligations of audited taxpayers. The second is a referral to the departmental commission for direct taxes and turnover taxes, for questions of fact within its remit (articles L. 59 and L. 59 A LPF).

  • What the firm does: picks the most useful route for the dispute, prepares the file and the hearing.
  • Next step: the commission’s opinion, then collection of the amounts upheld.

Formal claim, stay of payment and court

Once the tax has been put into collection, you can file a formal tax claim (réclamation contentieuse), generally until 31 December of the second year following the year of collection or of notification of the notice of collection (article R. 196-1 LPF). An express request for a stay of payment included in the claim suspends payment of the disputed tax, although security may be required (article L. 277 LPF).

  • What the firm does: drafts the claim and the stay request, then brings proceedings before the administrative court and, if needed, the administrative court of appeal.
  • Penalties: the 40% (deliberate failure) and 80% (fraudulent schemes) surcharges under article 1729 of the French Tax Code (CGI) are reviewed separately from the tax itself.
  • Next step: see our fees or schedule an appointment for an initial assessment.

French tax audit time limits, from notice to court

These are the standard time limits of the LPF as commented in the BOFiP. Extensions and exceptions apply depending on the procedure and the size of the business.

StageStandard time limitProvision
Notice of audit, before the first visitEnough time to allow you to arrange assistanceLPF art. L. 47
On-site accounting audit (turnover below the simplified regime thresholds)3 months maximumLPF art. L. 52
Remote accounting review (based on the accounting entries file, FEC)6 months from receipt of the files to issue a proposed reassessment or a no-reassessment noticeLPF art. L. 47 AA
Review of an individual’s personal tax situation (ESFP)1 year from receipt of the notice, unless extendedLPF art. L. 12
Your observations on the proposed reassessment30 days, extended by 30 days on request; with no reply, the adjustments are deemed tacitly acceptedLPF art. L. 57 and R.* 57-1
Tax authority’s reply to your observations (accounting audit or review of a small business)60 days; failing that, your observations are deemed acceptedLPF art. L. 57 A
Referral to the departmental tax commission30 days from the tax authority’s reply to your observationsLPF art. R.* 59-1
Formal tax claim31 December of the second year following collection; after a reassessment, a period equal to the one the tax authority hadLPF art. R.* 196-1 and R.* 196-3
Application to the administrative court2 months after the claim is rejected; possible once 6 months have passed without a decisionLPF art. R.* 199-1
Statute of limitations for the tax authority (income tax, corporate income tax)End of the third year following the tax year; 10 years in particular for undeclared foreign assetsLPF art. L. 169

Desk audit, remote accounting review, ex officio assessment. A desk audit (contrôle sur pièces) is carried out from the tax office, based on your returns and the information the tax authority already holds; it can lead to a request for information or straight to a proposed reassessment. A remote accounting review (examen de comptabilité) is an audit conducted at a distance: the business sends a copy of its accounting entries file and the auditor does not visit. An ex officio assessment (taxation or évaluation d’office) applies in particular when a return has not been filed and the failure has not been put right within thirty days of a formal notice. The taxpayer then loses part of the safeguards of the adversarial procedure and must prove that the assessment is excessive (article L. 193 LPF).

Expertise

Our Expertise in Tax Audit and Litigation

The firm handles the full range of tax audit and litigation matters, from the receipt of a notice of audit to proceedings before the tax courts.

Assistance and Preparation During a Tax Audit

A tax audit cannot be improvised: the way you answer the first requests often shapes the final outcome.

  • Checking that the notice of audit is valid (mandatory statements, time allowed before the first visit)
  • Upfront review of the tax position of the business or individual
  • Preparing and organizing the documents requested by the auditor
  • Strategic advice on dealing with the tax authority, to avoid mistakes that make matters worse

Objectiveto anticipate difficulties and limit the risk of a reassessment.

Replying to a Proposed Reassessment

The proposed reassessment (proposition de rectification, often called a redressement) is the document in which the tax authority sets out the amounts claimed. A weak or late reply can leave the adjustments in place: without a reply in time, they are deemed accepted.

  • In-depth review of the grounds relied on by the tax authority
  • A legal, figures-based reply that exposes the weaknesses in its reasoning
  • Reliance on case law and tax legislation to strengthen the defense

Objectiveto have the proposed adjustments reduced or withdrawn.

Administrative Appeals and Tax Commissions

If you still disagree, several remedies are available before going to court.

  • Appeal to the auditor’s superior
  • Referral to the departmental commission for direct taxes and turnover taxes (CDI), which has jurisdiction over certain technical disputes
  • Negotiation strategy aimed at an amicable settlement

Objectiveto use every internal avenue of challenge and avoid long and costly litigation.

Litigation Before the Tax Courts

When discussions with the tax authority fail, the case can go to court. This is an area where technical skill and procedure are decisive.

  • Filing a formal tax claim in proper form
  • Representation and oral argument before the administrative court or the administrative court of appeal
  • Litigation strategy built on sound legal arguments and close monitoring of case law

Objectiveto seek a substantial reduction or the full discharge of the disputed assessments.

Defense Against Tax Penalties and Criminal Tax Proceedings

Tax reassessments often come with penalties, and sometimes with allegations of tax fraud.

  • Challenging surcharges for bad faith or deliberate failure
  • Reduction of late-payment interest and tax fines
  • Criminal defense in tax fraud prosecutions, in coordination with the competent courts

Objectiveto protect not only your finances but also your reputation and your exposure to criminal liability.

Why Choose VV Avocat for Your Tax Litigation?

Choosing VV Avocat, tax lawyer in Toulouse, means opting for a proactive and personalized defense:

  • Experience in tax litigation, with clients including companies, executives and individuals.

  • Risk anticipation: we identify procedural flaws, which are often decisive when challenging a reassessment on the merits or on procedural grounds.

  • A single strategy: every stage (audit, appeals, litigation) is handled as part of one consistent plan.

  • Bilingual French/English support: ideal for foreign investors or expatriates facing a tax audit in France.

  • Clear information: each stage, each exchange with the tax authority and each procedural option is explained to you.

The firm handles both the audit phase (the audit itself and replies to the tax authority) and the litigation phase before the tax courts.

Corporate Tax Lawyer Toulouse
To Learn More

Case studies

Case Studies in Tax Audits and Litigation

The cases below are based on matters actually handled by the firm. Amounts have been changed and identifying details removed to protect client confidentiality.

  1. Amount at stakeEUR 649,720

    Inheritance Tax (Reassessment Partly Cancelled)

    Situation

    In a tax audit of an estate, the tax authority took the view that the declared value of a villa in a sought-after area of the French Riviera was below its market value.

    A reassessment of EUR 649,720 was proposed.

    A detailed valuation analysis was carried out, based on comparable sales, the specific features of the property and actual conditions in the local property market.

    Outcome

    The reassessment was limited to EUR 211,917, a reduction of EUR 437,803.

  2. Amount at stakeEUR 145,520

    Real Estate Capital Gains (Main Residence)

    Situation

    The tax authority challenged the capital gains exemption on the ground that the property was not the taxpayer’s main residence.

    Proposed reassessment: EUR 145,520.

    Outcome

    After an exchange of arguments with the tax authority and production of the necessary evidence, the reassessment was dropped in full.

  3. Amount at stakeEUR 121,124

    Withholding Tax and Cross-Border Payments

    Situation

    Audit of withholding tax on payments made to a Swiss software supplier.

    The tax authority argued that the sums paid were royalties taxable in France. Amount of the reassessment: EUR 121,124.

    Outcome

    The tax authority’s characterization was successfully challenged. The reassessment was dropped in full.

FAQ: Tax Audit and Litigation

Is it Mandatory to Have a Lawyer During a Tax Audit?

No. Being assisted by counsel is a right of the audited taxpayer, not an obligation: the notice of audit must state, on pain of nullity of the procedure, that you may be assisted by counsel of your choice (article L. 47 LPF). In practice, a tax lawyer secures the audit from the very first letter: checking that the notice is valid, framing exchanges with the auditor, preparing the documents to be handed over and building the reply to the proposed reassessment, through to litigation if necessary.

You have 30 days from receipt, extended by 30 days if you ask before the deadline expires (articles L. 57 and R.* 57-1 LPF). If you do not reply in time, the adjustments are deemed tacitly accepted: you can still challenge them through a formal claim, but the burden of proof will then be on you.

The tax authority puts the amounts into collection and sends you a demand for payment (for example a notice of collection, avis de mise en recouvrement). You can then file a formal tax claim.

Yes, certain surcharges can be challenged if the tax authority fails to prove bad faith or if the procedure was irregular.

Yes, particularly where there are significant real estate holdings, financial investments, foreign bank accounts or income from cryptocurrencies.

The amounts become payable once they are put into collection, at the end of the reassessment procedure. If you dispute them, your formal claim can include an express request for a stay of payment: it suspends payment of the disputed tax until a decision is made, although the public accountant may require security (article L. 277 of the French Tax Procedure Code). The firm makes this request in the claim itself, to prevent enforcement measures while the dispute is ongoing.

For income tax and corporate income tax, the tax authority can generally make adjustments until the end of the third year following the year for which the tax is due (article L. 169 of the French Tax Procedure Code). This period is extended to ten years in certain cases, in particular where accounts, life insurance policies or trusts held abroad were not declared. The first thing we check in a proposed reassessment is therefore that the years concerned are not time-barred.

It takes the form of a review of your personal tax situation (ESFP): the tax authority compares your declared income with your bank accounts and lifestyle, and sends you requests for clarification or justification. As a rule, the review cannot last more than one year from receipt of the notice (article L. 12 of the French Tax Procedure Code). You can be assisted from the very first letter; the firm prepares the evidence and the written replies with you.

It is the procedure by which the tax authority sets the tax base itself, in particular when a return has not been filed and the failure has not been put right within thirty days of a formal notice, or when an individual does not answer requests for clarification or justification during an ESFP. The taxpayer then loses part of the safeguards of the adversarial procedure and must prove that the assessment is excessive (article L. 193 of the French Tax Procedure Code). The firm first checks that the conditions for an ex officio assessment were met, then rebuilds the actual tax base from your evidence.

Schedule an Appointment

Further Reading