Extension of the Deadline for Completing an ESFP: But You Still Have to Prove It

A taxpayer was subject to a review of his personal tax situation, following whichadministration notifiedadministration of a tax assessment.

The reassessment was challenged all the way to the Administrative Court of Appeals.

In particular, the taxpayer argued that the procedure was improper becauseadministration comply with the maximum time limit for conducting the review of his personal tax situation.

Article L.12 of the Code of Tax Procedures provides thatadministration a maximum of one year to conduct this audit. However, this time limit is extended under certain circumstances.

During the tax audit in question,administration requested information from the British authorities in March and May 2011. The reassessment proposal stated that they had received responses in April and June 2011.

The reassessment proposal, dated July 2, 2012, was therefore issued after the deadline by whichadministration was requiredadministration complete the taxpayer’s tax audit.

However,administration before the Court that it had received the final response to its May 2011 request on February 13, 2012, and that the deadline had been met.

The Court will note, however, thatadministration hasadministration provided any evidence to support this assertion.

It therefore ruled that the time limit within whichadministration were requiredadministration conduct the taxpayer's tax audit had expired.

The tax assessment related to this irregularity is therefore rescinded.

CAA Paris, July 3, 2026, No. 24PA02215

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