Whenadministration a tax assessment against a delinquent taxpayer

A company named "SASU A"—where "A" is the name of its shareholder—was subject to a tax audit, following whichadministration issued a VAT assessment.

Since the company had not paid the assessment, the public accountant sought to place a provisional attachment on its assets.

The company contested this seizure, arguing in particular that the tax assessment had been virtually entirely dropped byadministration.

The tax authority had in fact sent a tax refund notice to Company A, which, according toadministration, should actually have been addressed to its shareholder, Mr. A, who operated a sole proprietorship at the same address.

The Administrative Court of Appeals will note, however, that no new notice had been issued to collect the tax assessment against the company.

Thus, since the amount of the tax assessment had been reduced by the time the accountant initiated the provisional attachment, he was not entitled to proceed with it.

The Court therefore relieves the company of its obligation to pay the amount of the tax assessment that has been rescinded.

CAA Lyon, Nov. 6, 2025, No. 24LY02118

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