For debt collection purposes, the date of notification of a registered letter is the date the letter is picked up
Following several tax audits, a taxpayer was notified of various tax assessments between 2013 and 2014. Since she had not paid these assessments, the public accountant sent her several formal notices on June 16, 2021, against which she filed an objection to enforcement on July 20, 2021.
These formal notices were sent by certified mail, postmarked by the postal service on June 21, 2021. The taxpayer was notified on June 23 and picked up the notice at the post office on July 1.
The Administrative Court of Appeals, in ruling on the taxpayer’s request for relief from the obligation to pay, first noted that the various interruptions of the statute of limitations had extended the statute of limitations for the collection action to June 24, 2021.
It then notes that Article R.257-0 A of the LPF refers to Article R.256-7 of the same code to determine the effective date of a formal notice to pay.
This provision states that "tax bill deemed to have been served: (a) if the copy was actually delivered by the postal service provider to the taxpayer or his authorized representative, on the day of such delivery; (b) if the registered letter could not be delivered due to the taxpayer's fault, on the day of the first attempted delivery."
The Court therefore concludes that, when a taxpayer is notified by registered letter and subsequently picks up the letter at the post office, the date on which the letter is delivered is the date to be taken into account for the purpose of interrupting the statute of limitations through a formal notice.
Thus, in this particular case, although the taxpayer was notified by the mail carrier on June 23 that a registered letter was waiting for her, she did not receive the letter until July 1.
However, by that date, the statute of limitations for theadministration collection actionadministration expired.
The Court hereby discharges the obligation to pay.
CAA Paris, Jan. 16, 2026, No. 24PA02159
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