You are here:

Tax litigation

Expertise dedicated to defending our clients

The firm assists clients throughout litigation before French courts and institutions, including administrative courts, civil and criminal courts and the Constitutional Council (Conseil constitutionnel), and before European courts, including the Court of Justice of the European Union and the European Court of Human Rights.

First, the firm assists clients in challenging the substantive validity of taxes assessed by the French tax authorities (tax assessment disputes, or contentieux de l’assiette). If you wish to challenge the findings of a tax audit, we support you in doing so.

The firm also assists clients in challenging enforcement measures taken by the French tax authorities to collect tax debts (tax collection disputes, or contentieux du recouvrement). In particular, we check that the authorities’ right to collect the debt is not time-barred. Tax collection disputes require precision and prompt action: collection measures may be challenged only within two months of notification. If you are concerned about measures taken by the French tax authorities to recover old tax liabilities, we can assist you.

In tax matters, proceedings before the competent court must first be preceded by a formal administrative tax claim, which defines the scope of the taxpayer’s challenge. Assistance from a tax lawyer from the initial filing of that claim is therefore important to ensure compliance with the applicable procedural rules.

Our assistance covers the following:

Drafting the formal claim submitted to the French tax authorities

The firm formalises the taxpayer’s challenge both procedurally, ensuring compliance with jurisdictional and procedural rules, and substantively, setting out the grounds of challenge.

Bringing proceedings before the competent courts

The firm initiates proceedings before the competent courts and handles the case throughout the litigation, including receiving defence submissions, drafting replies and attending hearings. The firm can act throughout France, including mainland France, Corsica and the overseas territories. We also assist clients with appeals against judgments and handle matters before the Conseil d’État, France’s highest administrative court, or the Cour de cassation, its highest court in civil and criminal matters.

Are you involved in a dispute with the French tax authorities?