Whenadministration to seize six times more than the taxes owed

CAA and TA
Written by Paul Mispelon

A company executive had been held jointly liable for his company’s tax debt. To recover these funds, the public accountant sent a formal notice to the taxpayer. He then issued an administrative garnishment order against a third-party holder for approximately 270,000 euros.

The executive challenged the decision in court.

The Administrative Court of Appeals then noted that the formal notice demanded payment of approximately 270,000 euros. It included a table showing how this amount was calculated.

The Court notes, however, that the letter specifically stated that "the amount of duties and penalties subject to criminal prosecution and remaining due as of February 5, 2019, is 25,563.49 euros in duties and 16,440 euros in penalties."

The executive stated that these amounts remained unpaid, and the Minister did not contest these claims in court.

The Court therefore sets aside the garnishment order to limit the amount to these amounts.

CAA Lyon, Dec. 4, 2025, No. 24LY01355

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Paul Mispelon
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