When you receive a reassessment proposal is important to respond in writing; otherwise, you will be deemed to have accepted the reassessment.

You have 30 days to submit your comments. The 30-day period begins upon receipt of the reassessment proposal LPF, Art. L.11).

Within this 30-day period, you may also request an additional 30 days to respond to the reassessment proposal. In that case, you will have 60 days to submit your comments (LPF, Art. L.57).

To obtain this extension, you must send a letter—preferably by certified mail with return receipt requested to ensure you have proof of delivery—to the inspector whose address is listed on the reassessment proposal. Instead of registered mail, you can also send an email to the inspector asking them to confirm receipt so that you have proof that they received the document.

When you receive the reassessment proposal, you may request to resolve your situation in order to qualify for a reduction in late payment interest.

It is advisable to consult an attorney as soon as you begin drafting your response so that the attorney can verify theadministration calculationsadministration formulate the most appropriate response.

You have 30 days to submit your comments. The 30-day period begins upon receipt of the reassessment proposal LPF, Art. L.11).

Within this 30-day period, you may also request an additional 30 days to respond to the reassessment proposal. In that case, you will have 60 days to submit your comments (LPF, Art. L.57).

To obtain this extension, you must send a letter—preferably by certified mail with return receipt requested to ensure you have proof of delivery—to the inspector whose address is listed on the reassessment proposal. Instead of registered mail, you can also send an email to the inspector asking them to confirm receipt so that you have proof that they received the document.

It is important to respond in writing to the reassessment proposal to contest the entire tax assessment. You have 30 days to submit your comments, with the option to request a 30-day extension of this deadline (LPF, Art. L.57).

To challenge the tax assessment, you can start by stating whether you disagree with theadministration description of the situation. For example, if the tax authority believes that you sold your home but that it was not your primary residence, you can challenge this assessment and provide supporting documentation.

Next, you can challenge the law applied by the tax authorities if you believe they did not apply the correct section of the General Tax Code. You can also challenge the tax authorities’ interpretation of the law.

To contest the reassessment proposal, you must submit written comments to the tax inspector who signed the reassessment proposal.

You have 30 days from the date of receipt of this document to submit your comments toadministration LPF, Art. L.11).

Within this 30-day period, you may also request an additional 30 days to respond to the reassessment proposal. In that case, you will have 60 days to submit your comments (LPF, Art. L.57).

Whenadministration realizes that there is a procedural irregularity and that it is still within the time limit to correct the error, it attempts to rectify the situation by sending a new reassessment proposal “CANCELED AND REPLACED.”

In this situation, however, it is necessary to verify whetheradministration respected the safeguards afforded to the taxpayer when it resolves the matter.

administration also sometimesadministration “cancel and replace” correction proposals when it has previously issued a reassessment proposal the statute of limitations and wishes for the tax adjustment to be based solely on that reassessment proposal.

Whenadministration a tax audit (usually an examination of the taxpayer’s books) and are pressed for time due to the statute of limitations for one of the years under review, they generally send the taxpayer a notice to interrupt the statute of limitations, which applies only to the year that is at risk of becoming time-barred.

This “cancel and replace” proposal allowsadministration ensure that they can reassess the business or individual at a later date and continue the tax audit for other years.

However, it is important to respond to this reassessment proposal carefully reassessment proposal , even though its sole purpose is to suspend the statute of limitations, it has the same legal effect as a reassessment proposal . If the taxpayer fails to respond, the taxpayer is deemed to have accepted the adjustments.

Generally, notices of assessment are sent byadministration certified mail with return receipt requested.

If you have not received the registered letter or been notified that you need to pick up a registered letter at the post office, the procedure leading to the adjustment may be irregular.

administration , however, remedy this procedural defect within a certain time limit.

No, the reassessment proposal , in theory, just that—a proposal. However, once you receive it,administration will likely askadministration to pay the additional tax amount specified in that “proposal.”

Payment must be made upon receipt of thetax bill.

In the case of income tax, if an individual is subject to a tax audit, the payment due date is generally listed in the letter accompanying the tax assessment notice.

With regard to corporate income tax, if a business or corporation is subject to a tax audit, you are generally required to make payment without delay. You typically have about 30 days to settle the amount owed.administration may sendadministration a formal demand for payment if they believe the payment should be made sooner.

If you later wish to contest the tax assessment and do not wish to pay the taxes, you may request a payment extension.

You are not required to have a lawyer assist you in responding to the reassessment proposal.

Nevertheless, involving an attorney as early as possible in the proceedings helps ensure that the amounts claimed byadministration been calculated correctly and may thus limit the impact of the assessment.

This also makes it possible to consider corrective procedures if an error has been made.

Above all, having a lawyer involved as early as possible in the tax audit ensures that the procedure is conducted properly and that the taxpayer is able to benefit from all the safeguards to which they are entitled.

Statutes of limitations for tax matters vary depending on the type of tax; they can be 3 years, 5 years, or even 10 years in certain circumstances.

The law generally provides that the time limit within which the tax authorities must notify you of an assessment expires in the following cases:

• Income tax and the special surtax on high incomes (LPF, Art. L.169, para. 1): December 31 of the third year following the year for which the tax is due (e.g., for 2020 income, reported in 2021,administration until December 31, 2023, to issue a tax assessment).

• the real estate wealth tax (IFI):

  • December 31 of the third year following the filing of the declaration regarding the value of the items listed in the declaration (LPF, Art. L.180 LPF)

  • on December 31 of the sixth year following the year for which the IFI is due, for items not included in the return or if no return has been filed (LPF, Art. L.186).

• Corporate income tax (LPF, Art. L.169, para. 1): December 31 of the third year following the end of the fiscal year (e.g., if a company’s fiscal year ends on December 31, 2020,administration until December 31, 2023, to issue a tax assessment. The same applies if the company closes its fiscal year on June 30, 2020).

• the research tax credit (LPF, Art. L.172 G): December 31 of the third year following the year in which the special return for this tax credit is filed (e.g., a company with a fiscal year-end of December 31, 2023, files its tax return in 2024 along with the return for the research tax credit;administration until December 31, 2027, to issue a tax assessment).

• VAT (LPF, Art. L.176) or the tax on insurance contracts (LPF, Art. L.182): December 31 of the third year following the year in which the tax became due. The due date for VAT depends on the transactions carried out (sale or delivery of goods, provision of services, importation, exportation, etc.)

• registration fees, inheritance taxes, or gift taxes:

  • on December 31 of the third year following the registration of the deed or declaration, when, to put it simply, the property has been properly declared but its value is incorrect (LPF, Art. L.180).

  • on December 31 of the sixth year following the registration of the deed or declaration, for property or assets not listed in the declaration (LPF, Art. L.186).

• withholding taxes (LPF, Art. L.169 A): the third year following the year for which the tax is due

• property tax (LPF, Art. L.173): December 31 of the year following the year for which the tax is due (e.g., for the 2023 property tax, paid in 2023,administration until December 31, 2024, to issue a tax assessment).

• the CVAE and the CFE (LPF, Art. L.174): December 31 of the year following the year for which the CVAE or the CFE is due.

Under certain circumstances (unreported income, undeclared foreign bank accounts, international administrative assistance, etc.), the statute of limitations may be extended, and the time limits mentioned above do not apply.