Commentary on articles regarding tax litigation under the Finance Act in the Tax Law Review

Publications

March 20

I am pleased to comment, in the second special issue of the Revue de droit fiscal devoted to the 2025 Finance Act, on the new provisions regarding tax litigation.

While the provision regarding the ex ante review of tax credits and withholding taxes is expected to have little impact (Art. 60), the provision establishing a new recovery period when a taxpayer“claims a false tax residence abroad” could have more significant consequences. To determine this, it would be necessary to know exactly which situations this new recovery period applies to; however, as discussed in the article, this is far from clear and will require clarification from the tax court (Art. 61).

Enjoy reading, and a big thank you to the magazine's staff, who have worked tirelessly this year!

Individual Tax AuditTax audit of tax creditsRecovery periodTax DomicileFictitious tax residenceFictitious residence

Paul Mispelon

Commentary on articles regarding tax litigation under the Finance Act in the Tax Law Review

Decisions by the Paris Administrative Court of Appeal regarding Article 123 bis, the SIIC regime, and the annual office tax

Capital gains on a primary residence: when the taxpayer’s defense falls apart