
DA-Tax


Tax Litigation
This article is for general information only. You should not act or refrain from acting in reliance of it. You should always obtain professional advice on the facts of your particular case. Nothing in this article constitutes financial advice. The owner of this site accepts no liability.
Tax litigation is carried out in the Administrative Court and is mostly done on paper. The French Tax Administration FTA sets out its case against you in some detail. The quality of their work and research is usually impressive. It is important to go through their case very carefully as small points not raised earlier may be important.
Your response is also on paper. Generally you deal with the FTA's points in turn. However it is best to make general points such as your prior compliance in making Tax returns on time and following the French rules. You do not want to look like a dodgy foreigner who cuts and runs.
Good advice from French counsel is essential. You can use an avocat from anywhere in France. The major firms in Paris are very good but fees tend to be very high. You also normally get nothing like your fees back if you win. If you are a multinational company this is fine but further down the feeding chain competent specialists in provincial firms are fine.
You are normally told there is no point attending court. I always prefer to be there. I think it helps for the judges to take a look at you and realise you are trying to comply.
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