When the Failure to Specify the Number of Pages in a Document Leads to the Dismissal of a Tax Assessment

A company was subject to a tax audit, following whichadministration issued a tax assessment.

This was based on a reassessment proposal the company stated that it had received only 14 pages of it. According to the company, the pages that partially outlined the financial implications of the reassessment had not been provided to it.

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

She then pointed out that, althoughadministration a reassessment proposal to the Court, the space provided on the first page of that document had not been filled out byadministration .

She believes that the statement inviting the taxpayer to state his position regarding the application of the cascade mechanisms does not allowadministration argue that the taxpayer should have inferred that pages were missing and that the company should have taken steps to obtain the missing pages.

The Court therefore finds thatadministration evidence that these 6 pages were served.

It thereby revokes the assessments for which the financial consequences were not communicated to the taxpayer.

CAA Paris, June 18, 2026, No. 25PA03312

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