When a letter takes six months to reach theadministration and results in the assessment being invalidated

A company underwent a tax audit, following whichadministration notifiedadministration of their intention to increase its tax liability through a reassessment proposal June 2, 2020.

The company submitted its comments via registered mail posted on July 2, 2020, in which it indicated that it was submitting additional comments and requested access to the documents obtained byadministration its right of access.

This letter was not received byadministration January 15, 2021, after the company had received thetax bill. The letter was sent in response to a complaint filed by the company on January 13, 2021.

The Administrative Appeals Court then ruled that even though the company had not confirmed receipt of the letter andadministration assumed that the company did not wish to submit comments, the company was deprived of a due process guarantee.administration review the company’s comments before issuingtax bill.

The Court then ruled that the procedure was improper and overturned the assessment.

CAA Versailles, Oct. 7, 2025, No. 23VE01213

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