Tax Litigation
Tax litigation in France covers all procedures by which a taxpayer may challenge decisions of the tax administration: the preliminary claim (réclamation contentieuse), supervisory review, referral to the administrative or judicial courts. Effective tax defence requires thorough knowledge of procedural rules, taxpayer safeguards and case law, to challenge both the substantive merits and the formal regularity of assessments.
Our Approach
IC Avocats has recognised expertise in tax litigation, serving French and international clients facing high-stakes tax audits and disputes. Our firm intervenes at every stage, from initial discussions and negotiations with the French tax authorities during audits, through to defence before the national courts.
Our approach is proactive and rigorous: we systematically examine the procedural regularity of the administration’s actions, identify the strongest substantive arguments and build a consistent defence strategy across all levels of appeal.
Our Key Services
Assistance During Tax Audits
IC Avocats assists businesses and individuals during accounting audits and personal tax examinations, ensuring that all taxpayer safeguards are upheld.
- Discussions and negotiations with tax authorities during audits
- Analysis and response to proposed assessment notices
- Management of the adversarial procedure and exercise of supervisory reviews
- Requests to refer matters to the Tax Commission (Commission des impots directs)
Dawn Raids (Perquisitions)
IC Avocats assists clients during domiciliary visits and seizures carried out by the tax authorities under Article L. 16 B of the LPF.
- Immediate assistance during search and seizure operations
- Challenge of the authorisation order before the First President of the Court of Appeal
- Analysis of seized documents and defence strategy
Defence Before National Courts
IC Avocats defends clients before all courts with jurisdiction in tax matters, from the administrative tribunal to the Conseil d’Etat.
- Contentious preliminary claims and proceedings before administrative tribunals
- Appeals before administrative courts of appeal and cassation appeals before the Conseil d’Etat
- Representation before civil courts (registration duties, ISF/IFI)
- Emergency tax proceedings and applications for a stay of payment
Judicial Review and Constitutional Challenges (QPC)
IC Avocats brings proceedings against unlawful administrative decisions and raises priority constitutionality questions where tax legislation infringes fundamental taxpayer rights.
- Judicial review (recours pour exces de pouvoir) of tax authority rulings and instructions
- Priority constitutionality questions (QPC) in tax matters
- Challenges to administrative doctrines that conflict with statute or the Constitution
Regularisation of Foreign Assets and IFI
IC Avocats advises and assists taxpayers wishing to regularise their tax position, particularly regarding assets held abroad and IFI filing obligations.
- Audit of tax position and risk assessment
- Preparation and filing of amended returns
- Negotiation with the tax authorities on applicable penalties
- Regularisation of IFI and wealth-related filing obligations