The inclusion of a tax debt in the liabilities section of the ISF form interrupts the statute of limitations

Some taxpayers had filed their 2012 tax returns, but the tax assessment was not issued until 2020 due to a computer glitch.

administration they were able to collect these taxes as of that date because the taxpayers had listed, under liabilities on their wealth tax returns for 2014 through 2017, a debt titled "2012 income tax assessment." The tax authorities considered this listing to constitute an acknowledgment of debt and had suspended the statute of limitations.

The Administrative Court of Appeals, to which the case was referred, ruled that the mention of the debt in 2014 had indeed interrupted the statute of limitations. It further held that the references in subsequent tax returns cannot be considered confirmatory acts.

Accordingly, it ruled thatadministration entitled to collect the taxes more than seven years after the taxpayers filed their returns.

CAA Paris, March 12, 2026, No. 24PA01802

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