Lobe Law offers comprehensive assistance with tax audits and tax litigation. With a particular attention to detail and a thorough understanding of the tax laws in force, Lobe Law can offer its clients precise and personalised advice to deal with any tricky tax situation.
Lobe Law's services cover the entire process, from the initial stages of a tax audit through to any litigation. Whether responding to requests from the tax authorities, contesting tax reassessments or defending clients' interests before the administrative or judicial courts, Lobe Law is there to provide effective and strategic representation.
Lobe Law understands the importance of tax issues to its clients and is committed to supporting them at every stage of the process, ensuring that their rights are protected and their interests vigorously pursued. Thanks to its experience in tax litigation, Lobe Law can provide innovative and effective solutions to resolve the most complex tax disputes.
The procedure varies according to the type of audit. The company may first receive a notice informing it that the French tax authorities intend to conduct an audit. The tax auditor then reviews the company’s tax returns, accounts and supporting documents, either on the company’s premises or remotely, depending on the procedure. The company may provide explanations during the audit. If the authorities identify potential irregularities, they may issue a reasoned proposed reassessment. The company is then given time to submit its observations. The audit may end without any adjustment or result in additional tax assessments and possible appeal proceedings.
A tax lawyer helps the company understand the scope of the audit and organise its defence from the first exchanges with the tax authorities. The lawyer reviews the requested documents, ensures that procedural safeguards are respected and prepares the company’s responses to the tax auditor. If a proposed reassessment is issued, the lawyer examines its legal grounds and calculations before submitting reasoned observations. The lawyer may also assist the company during hierarchical reviews, negotiations and subsequent litigation in order to protect its rights and defend its interests.
A company may begin challenging a reassessment upon receiving the proposed adjustments. It can accept the corrections or submit reasoned observations within the specified period, which is generally thirty days and may, under certain procedures, be extended by a further thirty days upon request. The company may provide supporting documents and challenge the facts, the interpretation of tax law or the calculation of the amounts claimed. Once the additional tax has been assessed, an administrative tax claim may be filed. If the dispute remains unresolved, the company may bring the matter before the competent court.
A company benefits from several safeguards during a tax audit. It must be informed of the nature of the audit and may be assisted by an adviser of its choice. It has the right to provide explanations, submit supporting documents and respond to the proposed adjustments. Any proposed reassessment must be sufficiently reasoned to enable the company to present meaningful observations. Depending on the procedure and the nature of the disagreement, the company may also request a hierarchical review or refer certain matters to the relevant commission. Compliance with procedural deadlines and the adversarial nature of the audit should be verified throughout the process.
A tax audit is the stage during which the tax authorities examine the company’s returns, accounts and overall tax position. It may end without any adjustment or result in a proposed reassessment. Tax litigation begins when a disagreement remains concerning the additional taxes or penalties claimed. It may involve an administrative stage, including the filing of a formal claim with the tax authorities, followed by proceedings before the competent court. A tax lawyer may intervene during the audit to help prevent a dispute and later during the litigation process to challenge the assessments.
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