Our expertise

Litigation

Arfé Avocats has a rigorous and committed practice in tax litigation, whether assisting during tax audits of individuals and companies or pursuing disputes initiated by our clients to challenge an assessment.

The firm is distinguished by its handling of high‑stakes tax disputes. We address complex tax issues that may have an international dimension.

We assist you throughout the tax procedure, from pre‑contentious exchanges with the tax authorities through to proceedings before administrative and civil courts.

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Tax audits — individuals

Arfé assists individuals who are the subject of a tax audit.

A tax audit enables the tax administration to verify an individual’s fiscal situation, in particular the regularity and consistency of their tax returns in light of French tax rules.

An individual’s tax audit may be conducted in the presence of the taxpayer (ESFP — “Examen contradictoire de situation fiscale personnelle” – Adversarial examination of personal tax situation) or remotely from the auditor’s office (inspector or controller).

To cope with this process, our firm advises and represents you throughout the audit procedure in your best interests.

Our commitments in the event of an audit:

  • A direct telephone line to communicate with your lawyer
  • A lawyer expert in tax audits with in‑depth knowledge of individual taxation
  • Use every means to have your situation understood and recognised by the tax administration
  • Seek a solution to reduce the financial impact of any adjustment and penalties, or to have them annulled, whether by negotiation or litigation

Our assistance specifically includes:

  • Preparing and accompanying the taxpayer before the first meetings with the tax inspector
  • Challenging the proposed tax adjustment by raising procedural and substantive grounds
  • Requesting and representing the taxpayer before the auditor’s superior or the departmental contact (hierarchical appeal)
  • Assisting the taxpayer before the various commissions (departmental conciliation commission, committee on abuse of tax law)
  • Preparing and filing a contentious claim to contest all or part of the audit
  • Bringing and negotiating with the tax conciliator or the mediator at the Ministry of Finance
  • Bringing proceedings before the courts (administrative or civil) to defend the taxpayer

Tax audits — companies

We assist companies and entrepreneurs involved in tax audits in France.

These audits generally take the form of “accounting verifications” (“vérification de comptabilité”).

The assistance of a lawyer is, in our view, essential in many cases to assert the rights of the company or entrepreneur and to ensure that all safeguards governing the tax audit are respected.

Our commitments in the event of a tax audit:

  • A direct telephone line to communicate with your lawyer
  • A lawyer expert in tax audits with in‑depth knowledge of corporate taxation
  • Use every means to have your situation understood and recognised by the tax administration
  • Seek a solution to reduce the impact of any adjustment and penalties, or to have them annulled, whether by negotiation or litigation

In this context, our assistance consists in particular of:

  • Preparing and accompanying the company before the first meetings with the tax inspector
  • Challenging the proposed adjustment by raising procedural and substantive grounds
  • Requesting and representing the company before the tax inspector’s superior or the departmental contact (hierarchical appeal)
  • Assisting the company before the various commissions (direct taxes and turnover taxes commission, departmental conciliation commission, committee on abuse of tax law)
  • Preparing and filing a contentious claim to contest all or part of the tax reassessment
  • Bringing and negotiating with the tax conciliator or the mediator at the Ministry of Finance
  • Bringing proceedings before the courts (administrative or civil) to defend the company

General tax litigation

Arfé represents clients in pre‑contentious procedures before the tax administration and in contentious phases before the courts throughout France.

The firm also assists clients in criminal tax litigation (see the dedicated page).

  • Litigation claims
  • Assistance before commissions (direct taxes and turnover taxes commission, departmental conciliation commission)
  • Representation before administrative courts (administrative court, administrative court of appeal, Council of State)
  • Representation before civil courts (judicial court, court of appeal, Court of Cassation)

Training in tax litigation

Due to its expertise in tax litigation, the firm is occasionally called upon to provide training on tax procedure in different countries (for example: training on tax litigation in Guinea‑Conakry, Haiti, etc…).