Challenging the French tax administration amicably
Where a business disagrees with the French tax administration, several amicable routes exist before going to court, and they are not used at the same moment. DURING a tax audit: a first-level hierarchical appeal to the divisional or principal inspector named on the audit notice; then a second-level appeal to the departmental contact; then the ombudsman of the economic and financial ministries, which requires a hierarchical appeal to have been made first. OUTSIDE an audit: a request for relief to the business tax office, seeking a write-off or a reduction; then the departmental tax conciliator if the answer is unsatisfactory; then the ombudsman. Two traps dominate: a hierarchical appeal during an audit DOES NOT STOP the audit, and a request for relief GIVES NO RIGHT to defer payment — the tax is still demanded while it is considered.
Up to date for 2026 — verified on September 11, 2026Official procedure, no printed formGuide: about 35 min
Deadlines
- Request for relief: no time limit
- There is no time condition for sending a request for relief to the business tax office.
- Two months' silence = refusal of relief
- If the tax administration does not reply within 2 months, the request for relief is treated as refused.
- Settlement: 30 days to reply
- Where the administration accepts, it sends a proposal by recorded delivery; the business has 30 days from receiving the draft to give its acceptance or notify its refusal.
- Four months' silence = refusal of the settlement
- Silence from the administration for more than 4 months counts as refusal of the settlement request.
Documents to prepare
- The audit or accounts examination notice, which names the auditor's superiors and the departmental contact
- A description of the problem and the references of the department concerned
- Copies of the letters exchanged with the administration
- The details needed to identify the matter, for a request for relief
- Information on your financial position, which the conciliator takes into account
- A parallel request for time to pay, since the appeal does not suspend payment
No form is attached to this procedure: the link leads to the official page that describes it.
What this page gives you
The guide above and the link to the official site. ActioFin does not produce any document for this page: whatever you fill in or file is done on the official medium.
Who this applies to
- Businesses disagreeing with the tax administration during an audit, on substance as well as on how it is conducted
- Businesses in financial difficulty seeking a write-off or reduction of tax, fines, penalties or late-payment interest
- Businesses seeking to negotiate a reduction of penalties that are NOT final, through a settlement
- Businesses whose claim was rejected or only partly allowed, or whose request for time to pay was refused — the departmental conciliator's cases
- Businesses considering that the quality of service or the administration's service commitments were not met
Worked example
Example: Fonderie Blanchard, assessed and then short of cash
Fonderie Blanchard is subject to an accounts audit. Disagreeing about a provision being added back, its manager first writes to the divisional inspector named on the audit notice — a first-level hierarchical appeal, by letter or email. Differences remain: he goes to the departmental contact, whose name and address appear on the same notice. He notes that these steps do not stop the audit, which carries on. The assessment is upheld; to avoid litigation, the foundry proposes a settlement: it undertakes to pay the amount set and gives up any claim or appeal, the administration giving up in return, wholly or partly, the penalties, surcharges and late-payment interest. The administration accepts and sends its proposal by recorded delivery; the foundry has 30 days to reply. It also notes that the settlement does not stop the payment being demanded: so in parallel it asks for time to pay. Two years later, in financial difficulty over tax that has become final, it will send a simple letter of request for relief to its business tax office seeking a write-off.
How to fill it in, step by step
- Place the moment: during a tax audit the route is the hierarchical appeal; outside an audit it is the request for relief.
- During an audit, send a first-level hierarchical appeal, by post or email, to the auditor's superiors — divisional or principal inspector — whose names appear on the audit or accounts examination notice.
- If differences remain, go to the departmental contact, whose name and address appear on the same notice — that is the second-level appeal.
- Be aware that these appeals do not stop the audit, which carries on while they are considered.
- If the hierarchical appeal has failed, go to the ombudsman of the economic and financial ministries, online or by simple letter, attaching a description of the problem, the references of the department concerned, copies of the letters exchanged with the administration and your contact details.
- Outside an audit, send a request for relief as a simple letter to the business tax office you report to, giving the details needed to identify the matter — no time limit applies.
- Check that the tax can actually be written off: only FINAL tax and penalties qualify, and registration duties, stamp duties, land registration tax and turnover taxes are excluded.
- If the answer does not satisfy you, go to the departmental tax conciliator — after first contacting your business tax office — and then, if the dispute persists, to the ombudsman of the economic and financial ministries.
- Wherever payment is still demanded — request for relief, settlement — ask for time to pay in parallel.
The form, line by line
- First-level hierarchical appeal
- Sent by letter or email to the divisional or principal inspector, whose name appears on the audit or accounts examination notice.
- Second-level hierarchical appeal
- The departmental contact, whose name and address also appear on the notice. It is used where differences remain after meeting the inspector.
- Request for relief
- A simple letter to the business tax office, seeking a WRITE-OFF — giving up the whole amount — or a REDUCTION of tax, fines, penalties or late-payment interest. No time limit applies.
- The €300,000 threshold
- The decision rests with the departmental director of public finances for a request of €300,000 or less per tax year, which can be challenged before the minister for the budget; above that, the minister decides.
- Tax settlement
- It requires MUTUAL concessions and covers only fines and penalties that are NOT final: a settlement cannot be negotiated on the main tax itself.
- Departmental tax conciliator
- Competent on every tax where it results from adjustments following a desk audit, after an unsuccessful first approach to the business tax office.
- Ombudsman of the economic and financial ministries
- Approached online or by simple letter, after a hierarchical appeal during an audit, or after the conciliator outside one.
Good to know
- A hierarchical appeal made during an audit DOES NOT STOP the audit: its timetable runs on.
- A request for relief GIVES NO RIGHT to defer payment: the administration may still demand the tax despite the request.
- A settlement likewise does not stop the payment demanded — hence the value of asking for time to pay in parallel.
- Once a settlement is performed, the tax and penalties it covers can no longer be challenged before a judge: that is the price of the concession obtained.
- The conciliator weighs the request on several criteria: the business's financial position, how cooperative it was during the audit, whether the breach was isolated, and how convincing the explanations given are.
- Not every tax can be written off or reduced: registration duties, stamp duties, land registration tax and turnover taxes are excluded.
- In practice, whether to propose a tax settlement is assessed by the business's lawyers.
Common mistakes
- Waiting until the audit ends to object: the hierarchical appeal is made DURING it, to the superiors named on the audit notice.
- Assuming a hierarchical appeal suspends the audit: it does not.
- Going to the ombudsman of the economic and financial ministries without first making a hierarchical appeal: that step is required.
- Stopping payment while a request for relief is considered: it gives no right to defer payment.
- Seeking relief on tax that is not final: only final tax and penalties qualify.
- Seeking relief on a tax that is excluded — registration duties, stamp duties, land registration tax, turnover taxes.
- Negotiating a settlement on the main tax: it covers only fines and penalties that are not final.
- Letting the 30 days pass without replying to a settlement proposal received by recorded delivery.
- Taking the administration's silence as acceptance: two months without reply means refusal of relief, four months means refusal of a settlement.
- Going to the departmental tax conciliator without first contacting the business tax office.
Frequently asked questions
What routes are open during a tax audit?
A first-level hierarchical appeal to the divisional or principal inspector, a second-level appeal to the departmental contact, going to the ombudsman of the economic and financial ministries where the hierarchical appeal has failed, and a settlement, a written agreement ending a dispute.
What is a request for relief?
A request sent by simple letter to the business tax office, by a business in financial difficulty, seeking a write-off — giving up the whole of the tax, fines, penalties or late-payment interest — or a reduction. Only final tax and penalties qualify.
Is there a time limit for a request for relief?
No, there is no time condition. On the other hand, no reply from the administration within 2 months counts as refusal.
Must payment continue while the matter is considered?
Yes. A request for relief gives no right to defer payment, and a settlement does not stop the payment demanded: in both cases it is wise to ask for time to pay in parallel.
What can a tax settlement cover?
Only fines and penalties that are NOT final — the time limits for claiming must still be running. A settlement cannot be negotiated on the main tax itself.
When should the departmental tax conciliator be approached?
After first approaching the business tax office without satisfaction, in particular where a claim was rejected or only partly allowed, a request to write off penalties was refused, or time to pay was refused.
Go further
Compute the related amounts
Understand this form: the related course
Official sources
- entreprendre.service-public.gouv.fr — Dispute with the tax administration: how to seek an amicable remedy? (checked 1 May 2025): first- and second-level hierarchical appeals during an audit, names appearing on the audit or accounts examination notice, absence of any suspensive effect on the audit, going to the ombudsman of the economic and financial ministries after a hierarchical appeal, online or by simple letter with a description of the problem, the department's references, copies of letters and contact details; outside an audit, a request for relief by simple letter to the business tax office with no time condition, write-off and reduction limited to final tax and penalties, excluded taxes, decision by the departmental director up to €300,000 per tax year and by the minister above that, implied refusal after 2 months, no deferral of payment; settlements limited to non-final fines and penalties, mutual concessions, proposal by recorded delivery and 30-day reply period, implied refusal after 4 months, no further challenge before a judge; the departmental tax conciliator, when to approach them and the criteria applied — September 11, 2026
- entreprendre.service-public.gouv.fr — Obtaining time to pay from the tax administration (company), checked 27 November 2024: the step to take IN PARALLEL with a request for relief or a settlement, since neither stops the payment demanded — September 11, 2026
Guide and document provided for information purposes only; they do not constitute personalised legal or tax advice. Check the recipient organisation's requirements and consult a professional if needed.