Canadministration deny an appeal to a higher authority on the grounds that it would constitute an obstruction of a tax audit?

administration , believing that a Polish company had an undeclared permanent establishment in France, had launched a tax audit of the company, including an examination of its accounting records.

During the audit,administration a notice of objection to the audit on the grounds that the companyadministration refused, among other things, to produce its financial records.

The company then requested, through its attorney, a meeting with the auditor’s supervisor. The supervisor refused, stating that this guarantee would apply only in the event of an adversarial adjustment proceeding.

Since that ground for denial was erroneous,administration to argue that the request for an internal appeal "would have constituted conduct in opposition to the tax audit."

The Administrative Court of Appeals, to which the case was referred, will nevertheless rule that even if that were the case,administration entitled to deny the company the right to meet with its supervisor during the audit.

The tax assessment is therefore rescinded.

CAA Nancy, May 12, 2026, No. 25NC01665

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