Dispute resolution: litigation

Home visits based on mere suspicion of tax fraud

In two rulings handed down on February 15, 2023 (Cass. com., February 15, 2023, no. 20-20.599 and Cass. com., February 15, 2023, no. 20-20.600), the Commercial Chamber of the French Supreme Court confirms that the tax authorities can initiate home visits against a taxpayer on the basis of mere suspicions of tax fraud.

Tax lawyers’ professional secrecy: what are the limits when faced with the investigative powers of the tax authorities?

It is difficult to reconcile the rule of professional secrecy with the investigative powers of the administration. The question of compatibility for any investigative activity of the administration necessarily arises, and in particular for the right of communication.

Tax rescripts

It is often important to know in advance the position of the tax authorities on a factual situation presented to them, but also, more specifically, on the interpretation of a tax text or measure on which they have no position.

In this sense, a tax rescript is a response from the tax authorities to a question from the taxpayer concerning the interpretation of a tax provision in force, or a factual situation with regard to tax law.

The fight against tax fraud: what action has been taken on the recommendations of the Senate’s fact-finding mission?

In 2022, collections after tax audits reached 14.6 billion euros, i.e. 8.2% and 1.2 billion euros more than in 2021, according to the February 23, 2022 press release from the Ministry of the Economy and Finance.
An opportunity to take stock of the follow-up to the recommendations made by the information mission on the fight against tax fraud and evasion in its report of October 25, 2022.