Tax Audits & Litigation
At Axtead, we support individuals, executives, and corporations in all their dealings with the tax authorities—from initial inquiries to the audit phase and through formal tax litigation.
Our intervention can be proactive (preventive audits, tax rulings) or reactive (responding to ongoing audits, reassessments, or litigation).
We build clear, well-reasoned, and personalized defense strategies with a singular goal: to secure the taxpayer’s position while minimizing financial, tax, or criminal consequences.
Our Areas of Expertise:
- Preventive tax audits and rulings (rescrits) to anticipate risks and secure sensitive tax positions;
- Tax audit assistance: support during corporate accounting audits, individual tax audits (examen contradictoire de la situation fiscal personnelle–ESFP), remote audits, or formal requests for information and justification;
- Management of reassessment procedures: drafting responses to notices of reassessment, handling hierarchical appeals (principal inspector, departmental interlocutor), submission to consultative commissions (CDI, CNRAC, etc.);
- Negotiation with the tax authorities and seeking transactional solutions: settlement, waiver of surcharges and penalties, voluntary disclosures within a secure framework;
- Tax litigation: drafting formal tax claims, administrative appeals, providing representation before both Administrative and Judicial Courts;
- Assistance during tax raids (on-site searches and seizures under Art. L.16 B of the LPF) or prosecution for tax fraud.
Our approach is rooted in an in-depth understanding of tax legislation and administrative practices. We provide strategic, rapid, and effective intervention in high-stakes and sensitive cases.
Questions
Yes. A tax ruling (rescrit fiscal) is a valuable tool for securing a transfer structure, especially when it involves complex mechanisms or areas of uncertainty.
By submitting a formal written request to the tax authorities, you obtain an official position on how tax rules apply to your specific situation. This response is binding upon the administration, provided that the information disclosed is complete and accurate, and the circumstances remain unchanged.
At Axtead, we will help you determine the strategic relevance of a tax ruling. We assist in drafting the request to mitigate risks and proactively address sensitive issues.
Yes, ideally. Involving a tax attorney from the initial exchanges with the authorities allows to:
- Prepare documentation and responses strategically;
- Avoid inconsistencies or misstatements in declarations and interviews;
- Monitor the procedure to ensure legal boundaries are respected (deadlines, adversarial rights, and the scope of the audit);
- Anticipate potential reassessments to build a more effective defense.
Early legal intervention provides significant leverage for negotiation and security. It can effectively mitigate the consequences of a poorly initiated procedure.
In the event of a dispute following a notice of reassessment (proposition de rectification), several avenues of recourse are available:
- A reasoned response, filed within the prescribed deadlines, to contest all or part of the proposed adjustments;
- Hierarchical appeals to superior officers (principal inspector or departmental interlocutor);
- Referral to consultative tax commissions, depending on the nature of the dispute (e.g., the Direct Tax Commission or the Conciliation Commission);
- Filing a formal tax claim (réclamation contentieuse), followed, if necessary, by legal action before the Administrative or Judicial Courts.
At Axtead, we assist you at every stage of the process to assess your chances of success, defend your position with robust legal arguments, minimize reassessments, and, when necessary, initiate tax litigation under the most favorable conditions.
