Decision of the Paris Administrative Court of Appeal dated May 17, 2024
In a ruling dated May 17, the Paris Administrative Court of Appeal issued an interesting decision concerning, in particular, the application of the time limits for reassessment in cases where a complaint of tax fraudadministration to the opening of a criminal investigation (Article L.188 B of the General Tax Code).
It addresses both the retroactive application of these new provisions and the suspensive effect of proposed corrections with regard to the extension of deadlines.
The Court also rules on whether extending the time limits for appeals constitutes a penalty, and on the application of constitutional restrictions regarding the accumulation of surcharges.