---
title: "Tax Litigation"
id: "2013"
type: "expertise"
slug: "tax-litigation"
published_at: "2026-01-25T18:22:51+00:00"
modified_at: "2026-07-23T09:15:11+00:00"
url: "https://www.august-debouzy.com/en/expertise/tax-litigation/"
markdown_url: "https://www.august-debouzy.com/en/expertise/tax-litigation.md"
excerpt: "Securing your position in the most sensitive tax disputes Tax disputes involve significant financial, reputational, and strategic stakes. Tax audits, reassessments, searches, and judicial proceedings each require a technical and strategic defense to safeguard your rights. We intervene at every..."
taxonomy_language:
  - "English"
taxonomy_post_translations:
  - "pll_69765f7bec6c3"
taxonomy_tax_expertise:
  - "Tax litigation"
taxonomy_tax_famille_expertise:
  - "Dispute Resolution"
---

## Securing your position in the most sensitive tax disputes

Tax disputes involve significant financial, reputational, and strategic stakes. Tax audits, reassessments, searches, and judicial proceedings each require a technical and strategic defense to safeguard your rights.

We intervene at every stage, including assistance during audits, defense in the context of searches and seizures, administrative proceedings before the tax authorities, judicial litigation, and the handling of matters combining tax and criminal aspects.

Our approach combines mastery of tax procedures, in-depth knowledge of the internal functioning of the tax authorities, and a clear understanding of operational realities. We advise French and international companies, executives, shareholders, and investment funds. Working in close coordination with our white-collar team, we ensure a comprehensive and consistent defense strategy.

## *our*Capabilities

### (01) Tax Audits and Investigations

We assist clients during tax audits, accounting reviews, personal tax examinations, and desk audits. Our involvement includes analyzing requests from the authorities, preparing detailed and reasoned responses, negotiating with tax inspectors, and challenging reassessment proposals.

We anticipate potential reassessment risks, structure exchanges with the authorities, and safeguard our clients’ positions. This proactive approach limits tax exposure and helps prevent escalation into formal litigation.

### (02) Tax Searches and Investigative Procedures

Tax searches require immediate action to protect the rights of those concerned. We intervene on an urgent basis during investigative operations, assist executives and employees during questioning, challenge procedural irregularities, and ensure proper handling and preservation of seized documents.

Our knowledge of procedural safeguards and experience in investigative contexts help protect fundamental rights and mitigate the consequences of these intrusive measures.

### (03) Administrative Tax Litigation

We represent clients at all stages of administrative tax proceedings, including preliminary claims, hierarchical appeals, and appearances before tax commissions. Our strategy is aimed at securing full or partial relief from contested assessments through robust legal and factual argumentation.

Where appropriate, we also negotiate settlement solutions with the tax authorities when they better serve our clients’ interests. Mastery of administrative procedures maximizes the prospects of success and reduces the risk of escalation.

### (04) Judicial Tax Litigation and Criminal Tax Matters

We represent clients before all courts, including administrative courts, courts of appeal, the Conseil d’État, and criminal courts. Our expertise covers disputes relating to the assessment, calculation, or collection of taxes, as well as prosecutions for tax fraud.

In coordination with our white-collar crime team, we provide a comprehensive defense in matters combining tax and criminal issues. This integrated approach ensures strategic consistency and optimal protection before tax and criminal authorities.

Collective excellence

at the service of the

*highest standards.*

Team

[Philippe Lorentz ( Partner )](https://www.august-debouzy.com/en/collaborateur/philippe-lorentz/)

[Xavier Rohmer ( Partner )](https://www.august-debouzy.com/en/collaborateur/xavier-rohmer/)

[Elie Bétard ( Counsel )](https://www.august-debouzy.com/en/collaborateur/elie-betard/)

[Vincent Fromholz ( Associate )](https://www.august-debouzy.com/en/collaborateur/vincent-fromholz/)

[Théo Leclercq ( Associate )](https://www.august-debouzy.com/en/collaborateur/theo-leclercq/)

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## Contact Us

*Rankings*& Recognitions

m

- (01)Décideurs 2025 – France Tax Law
- (02)Option Droit & Affaires 2025 – France Tax
- (03)Décideurs 2024 – France Tax Law

[More distinctions](https://www.august-debouzy.com/en/distinctions/?search_tax-expertise%5B%5D=tax-litigation)

## *Latest* News

[29/08/25 Legal Article 6 min French Tax Authorities Release Draft Guidance on Management Packages On July 23, 2025, the French tax authorities released draft guidance clarifying the new tax regime for management packages (Article 163 bis H of the French Tax Code), detailing its scope, conditions, calculation method, and the allocation between capital gains and employment income.](https://www.august-debouzy.com/en/legal-article/french-tax-authorities-release-draft-guidance-on-management-packages/)

[10/02/25 Legal Article 5 min Overview on the new social and tax regime introduced by the finance act for 2025 reminders Article 93 of the Finance Bill for 2025 was adopted on Thursday, February 6. This article provides for the introduction](https://www.august-debouzy.com/en/legal-article/overview-on-the-new-social-and-tax-regime-introduced-by-the-finance-act-for-2025/)

[05/03/24 Legal Article 5 min Beyond the Olympic Games, France attracts large numbers of foreign athletes through a favourable impatriate tax regime At a time when the eyes of athletes all over the world are riveted on the Olympic Games, it is worth remembering that French tax legislation provides a ver](https://www.august-debouzy.com/en/legal-article/beyond-the-olympic-games-france-attracts-large-numbers-of-foreign-athletes-through-a-favourable-impatriate-tax-regime/)

[18/07/23 Deal 1 min August Debouzy advised TNP Consultants, a management consulting firm specializing in structural transformations. August Debouzy advised TNP Consultants, a management consulting firm specializing in structural transformations, in the acquisition of the Data Governance](https://www.august-debouzy.com/en/deal/august-debouzy-advised-tnp-consultants-a-management-consulting-firm-specializing-in-structural-transformations/)

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News

## *FAQ*

### (01) How can you anticipate tax litigation from the audit or accounting inspection stage?

Receiving notice of an accounting inspection or compliance review opens a process with significant financial and reputational stakes. Each audit stage (prior notice, conduct of operations, adversarial exchanges, proposed adjustments) follows strict procedural rules whose breach may invalidate the procedure. We assist clients from the moment the notice is received: document preparation, support during meetings with inspectors, analysis of proposed adjustments, reasoned responses to observations and activation of hierarchical appeals. The goal is to defend each position and contain exposure from the administrative stage.

### (02) How can you protect your rights during a tax dawn raid or investigation?

Tax dawn raids are the administration’s most intrusive enforcement tool. Article L. 16 B of the French Tax Procedures Code authorizes tax officials to conduct premises visits and document seizures, by order of the liberties and detention judge (JLD), where there are presumptions of fraud. We intervene within hours to assist teams during search and seizure operations, challenge the JLD’s order before the first president of the court of appeal, and protect defence rights. Every procedural irregularity identified serves as a basis to seek annulment of seized materials.

### (03) Within what time limit and under what procedure should you bring administrative tax litigation?

Challenging a tax reassessment before the courts requires first filing a contentious claim with the tax administration. Article L. 190 of the French Tax Procedures Code sets the claim deadline at 31 December of the second year following the year of the collection order or notice of assessment. We manage the entire litigation process: drafting claims, referral to departmental commissions, representation before administrative and judicial courts, and appeals before the Conseil d’Etat or the Cour de cassation.

### (04) What criminal penalties apply for tax fraud and how can you mount a defence?

Article 1741 of the French General Tax Code punishes tax fraud with five years’ imprisonment and a EUR 500,000 fine, which may be increased to twice the proceeds of the offence. In aggravating circumstances (organized crime, offshore accounts, forged documents), penalties rise to seven years’ imprisonment and EUR 3 million. Working with our white-collar crime specialists, we defend clients at every stage: police custody, judicial investigation and trial. We manage the tax and criminal dimensions simultaneously to ensure defence consistency.

### (05) Why choose August Debouzy as your law firm for tax litigation in France?

French and international companies, executives, shareholders and investment funds entrust us with their most sensitive tax cases. Our approach combines mastery of tax procedures, knowledge of internal administrative processes and understanding of operational stakes. We act at every stage: audit assistance, dawn raid defence, administrative and judicial litigation, and handling of combined tax and criminal cases. Working with our criminal law team, we deliver a comprehensive response that protects both tax positions and executives’ personal interests.