Skip to main content
Start free
Premium

French tax ruling request (rescrit fiscal) — BOFiP/DGFiP

Request a French tax ruling (rescrit fiscal, BOFiP procedure) to secure a tax arrangement with the authorities — binding reply within 3 months.

Who can file a rescrit fiscal request?

Any good-faith French taxpayer — individual, sole trader, or company — may submit a ruling request, provided the situation of fact is real, complete, and fully disclosed. The request must be filed before implementing the transaction in question and before any tax audit or verification notice has been issued.

Source: Légifrance — Livre des Procédures Fiscales, Articles L80 A and L80 B (general and specific tax rulings) · updated 2026

About this form

A rescrit fiscal (tax ruling) allows any French taxpayer — individual or business — to obtain a formal, binding position from the DGFiP (Direction générale des Finances publiques, France's tax authority) on how a specific tax provision applies to their particular situation, before they act on it. The procedure is entirely free. It is grounded in Articles L80 A (general ruling: interpretation of a tax provision) and L80 B (specific rulings covering CIR/R&D tax credit, JEI young-innovative-company status, zone exemptions, VAT, and charitable giving) of the Livre des Procédures Fiscales (LPF, France's Tax Procedures Code). The ruling is binding on the administration in any later audit. For the general ruling under L80 A, the administration's silence after 3 months does not constitute tacit approval — unlike certain specific rulings such as the CIR ruling under L80 B 2°, where silence means acceptance. The procedure applies only to future or ongoing situations not yet subject to a tax audit.

Worked example

Constructions Legrand SAS (revenue: €3.2 M, construction sector, Grenoble) plans to adopt a new prefabricated biosourced modular building method and wishes to qualify the associated R&D expenditure for the crédit d'impôt recherche (CIR, the French R&D tax credit). Before committing any spend, it files a CIR ruling (L80 B 2°, LPF) with the DRFIP Auvergne-Rhône-Alpes, attaching the technical description of the work, the list of research staff, and the projected budget. The administration does not respond within 3 months — silence constitutes tacit acceptance under L80 B. The CIR is secured for financial year 2026 with no risk of subsequent challenge on the declared elements.

How to fill out the form

  1. Identify the applicable ruling type — general ruling (L80 A LPF) for an interpretation question on any tax provision, or a specific ruling (L80 B) for listed schemes (CIR, JEI, zone exemptions, charitable giving, VAT) — and confirm that the situation is not already subject to a pending tax audit or verification notice.
  2. Draft the request as a free-format letter (no CERFA form required) setting out: the applicant's full identity (company name, SIREN registration number, registered address), an exhaustive and accurate description of the facts (parties involved, nature of the transaction, amounts, planned timeline), the relevant tax provision (code article, BOFiP guidance reference), and the precise legal question the administration is asked to answer.
  3. Send the request by LRAR (lettre recommandée avec accusé de réception — recorded delivery with acknowledgement of receipt) to the SIE (Service des Impôts des Entreprises) for the registered office or tax domicile, or to the Direction Régionale des Finances Publiques for complex cases; for CIR rulings, the request is addressed to the regional DGFiP directorate and may be accompanied by a scientific opinion from the MESR (Ministry of Higher Education and Research) for R&D work.
  4. Keep the LRAR receipt as proof of the submission date and count the 3-month deadline from the date the administration received the complete file; if the file is incomplete, the administration must notify missing items within a reasonable time, and the 3-month clock only begins from receipt of the completed dossier.
  5. After receiving a favourable ruling, retain the document permanently in the company's accounts or legal archives, comply with it strictly, and notify the administration without delay of any material change to the facts described; any change in circumstances requires a new ruling to be filed before proceeding with the modified transaction.

Good to know

  • File BEFORE any audit notice. A ruling submitted after receiving a vérification or contrôle fiscal notice is automatically inadmissible under art. L80 A LPF. If there is any doubt about whether such a notice has been issued, act immediately — do not wait.
  • The ruling's protection is directly proportional to the precision and sincerity of your factual description. Any omission — even unintentional — can void the binding guarantee. Always attach draft contracts, company statutes, financial schedules and any document needed to fully illustrate the transaction.
  • If the ruling is unfavourable, you have a right to a second review by the central administration under art. L80 CB LPF, requested within 2 months of the unfavourable response. This internal appeal is free, handled by a different officer, and requires no court proceedings.

Frequently asked questions

Who can file a rescrit fiscal request?

Any good-faith French taxpayer — individual, sole trader, or company — may submit a ruling request, provided the situation of fact is real, complete, and fully disclosed. The request must be filed before implementing the transaction in question and before any tax audit or verification notice has been issued.

How should the ruling request be drafted and submitted?

The request must set out the full facts (parties, transactions, amounts, planned timeline), identify the relevant tax provision, and pose a precise legal question. It is sent by LRAR (lettre recommandée avec accusé de réception — recorded delivery with acknowledgement of receipt) to the SIE (Service des Impôts des Entreprises, the local business tax office) with territorial jurisdiction, or to the Direction Régionale des Finances Publiques for complex cases. No CERFA form is required — a detailed free-format letter is sufficient.

What is the administration's response deadline, and does silence count as approval?

For the general ruling (L80 A LPF), the administration has 3 months from receipt of a complete request to respond; silence does not imply tacit approval. For specific CIR and JEI rulings (L80 B), the same 3-month period applies, but if the administration does not respond within that time, its silence constitutes tacit acceptance in the taxpayer's favour.

Is there any fee to file a tax ruling request?

No. The tax ruling procedure is entirely free of charge. No fee or processing duty is payable to the administration. Any costs incurred for professional advice — such as fees for a chartered accountant (expert-comptable) or a tax lawyer (avocat fiscaliste) — in preparing and drafting the request remain the taxpayer's own expense and are not reimbursed by the DGFiP.

What happens if the administration issues an unfavourable ruling?

An unfavourable ruling does not bind the taxpayer's own choices: the taxpayer may abandon the planned transaction, or proceed with it while accepting the risk of a later tax reassessment. The taxpayer may also request a second review by the central administration (art. L80 CB LPF) within 2 months of the unfavourable response. This internal appeal is free and handled by a different officer from the one who reviewed the initial request.

Does a favourable ruling provide protection in a later tax audit?

Yes — this is the core benefit of the mechanism. The administration cannot issue a tax reassessment on elements exactly as described in the request and covered by the favourable ruling. This protection is conditional on the accuracy and completeness of the factual description: any omission — even an inadvertent one — removes the taxpayer's binding guarantee and leaves them exposed to a standard reassessment.

Official sources

Updated on 2026-06-26

A question about this form?

Ask Solva, ActioFin's AI finance advisor — answers sourced from official texts.

5 free questions per day with a free account

Ask Solva

Useful calculators

Related forms

French tax ruling request (rescrit fiscal) — BOFiP/DGFiP