The signing of an unenforced settlement agreement interrupts the statute of limitations only at the time of its signing

A taxpayer who owed tax debts resulting from his father’s estate received two notices of garnishment from the taxadministration , seeking payment of those debts.

He challenged the validity of these documents in court, arguing that the statute of limitationsadministration had expired for bringing collection actions.

The Administrative Court of Appeals, to which the dispute has been referred, will then determine whether any acts that interrupted the statute of limitations would allow the debts to be considered not time-barred.

It notes that while the taxpayer did sign a payment plan, he did not fulfill it. It finds that the plan interrupted the statute of limitations on the day it was signed, since it constitutes an acknowledgment of debt on the part of the taxpayer, but that the failure to fulfill the plan cannot have any effect thereafter.

It further holds that voluntary payments made by the taxpayer to settle other tax debts cannot have interrupted the statute of limitations.

Finally, the Court notes that theadministration has not provided evidence that collection notices sent to banks or pension funds were duly served on the taxpayer. It points out that the fact that the mail was not returned with the notation “No longer resides at the address indicated” or “Mail undelivered” does not allow for the presumption that the notices were received.

The taxpayer is therefore relieved of the obligation to pay a portion of the tax debts that had become time-barred.

CAA Lyon, July 23, 2026, No. 25LY01659

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