Tax reassessment notice: responding within 30 days

Quick answer. You have 30 days to respond to a tax reassessment notice (proposition de rectification) issued under the adversarial procedure. This deadline can be extended by a further 30 days, for 60 days in total, on simple request made within the initial period. No response means tacit acceptance of the adjustments.

Receiving a tax reassessment notice often triggers a reflex to wait. That is precisely the mistake to avoid. The document opens a short deadline and, above all, failure to respond within it amounts to acceptance of the amounts notified. Understanding the clock that starts running, and organising your response, shapes everything that follows.

The proposition de rectification is the act by which the tax authority informs you, after an audit, of the adjustments it intends to make. Under the adversarial reassessment procedure, which is the standard procedure, it must be reasoned (LPF art. L. 57) so that you can submit your observations. The form generally used is model no. 2120-SD.

The standard response deadline is 30 days (LPF art. R*57-1). Under the adversarial reassessment procedure, you can extend it to 60 days by requesting a 30-day extension. This extension is granted as of right if the request is made within the initial 30-day period. You do not have to justify it.

This mechanism calls for a simple discipline: if the matter carries any stake, request the extension immediately, on receipt, without waiting to have built your arguments. The request preserves your room for manoeuvre while the analysis continues.

Watch out for an important exception. The 30-day extension does not apply under the automatic taxation procedure (imposition d'office). In that case, the protective adversarial framework does not operate in the same way, and the reflex to request more time does not produce the same effect.

Typical timeline of the adversarial procedure#

How you organise the first few days determines the quality of your defence. Here is the order of action we recommend in our files.

1. Note the date of receipt and immediately calculate the 30-day deadline. This is your central reference point.
2. Identify the procedure mentioned: adversarial reassessment or automatic taxation. This classification governs your rights, including the possibility of an extension.
3. Check the reasoning: the notice must set out the legal and factual grounds of the adjustments, tax by tax and year by year.
4. List the heads of adjustment, their base and their amount, then separate those you understand from those that call for clarification.
5. If the stake justifies it, send a 30-day extension request without delay, in writing, within the initial period.
6. Gather the supporting documents for each contested head: invoices, contracts, statements, accounting entries.
7. Prepare a written response, point by point, accepting what should be accepted and contesting what can be contested with reasoned arguments.

Responding does not mean contesting everything. A calibrated response distinguishes well-founded heads of adjustment from debatable ones. The table below summarises the options and their consequences.

These options are not mutually exclusive. You can accept some heads, contest others, and request the extension to gain time to examine the complex points.

In the files we handle, value lies less in rhetoric than in the quality of the documents. A well-built observation pairs a rule of law with concrete evidence. An argument of principle with no supporting document rarely shifts the auditor's position.

Our constant advice: never let the deadline slip through hesitation. Even a file where you think you are wrong deserves a response, because responding triggers the authority's duty to justify maintaining the adjustments, which clarifies the scope of the dispute and prepares any later remedies.

The most common trap is not poor argument, it is no response at all. Failure to respond within the deadline amounts to tacit acceptance. Many directors believe they have more time, or plan to react when the tax is collected. By then, acceptance is already settled on the heads not contested, and the discussion becomes far more constrained.

Second blind spot: mistaking a vague letter for a useful response. An effective response is structured, dated, head by head, and accompanied by documents. A letter that merely states disagreement without reasoning leaves the authority free to maintain its position.

Treat receipt as an internal procedure. Open a dedicated file, keep the envelope and the acknowledgement of receipt, and log every exchange. If your firm assists you, forward the notice on the day of receipt, not the day before the deadline. The response work needs time to collect and review documents, and is rarely compressible.

For VAT, deductibility or remuneration matters, the response gains from the accounting and tax analysis of the file. A VAT deduction point, for instance, is examined with the supporting documents for each operation concerned, as our guide on the deduction coefficient for a partial VAT taxpayer and our note on the VAT basic exemption explain. For director files, the trade-off between dividends and salary, or the taxation of the shareholder current account, often appear among the heads of adjustment.

• Not confirming the exact date of receipt, which starts the deadline running.
• Confusing the adversarial procedure with automatic taxation, when only the former allows the extension.
• Forgetting to request the extension within the initial period, which then makes it impossible.
• Responding globally instead of treating each head of adjustment separately.
• Neglecting to check the reasoning of the notice, tax by tax and year by year.
• Accepting adjustments by default for lack of time, when an extension was available.
• Underestimating the interruption of the limitation period, which changes the scope of the years at stake.

The auditor expects a precise response, backed by documents. On adjustments to deductible expenses or VAT, attention focuses on the reality, purpose and allocation of the operation. A response that produces the supporting documents and links each expense to the company's interest carries more weight than a contest of principle.

The financial stake is not limited to the principal. Late-payment interest applies at a rate of 0.20% per month, that is 2.40% per year. Depending on the breaches identified, surcharges may be added, for example in the event of deliberate breach. The exact amount of these surcharges depends on the classification adopted by the authority and appears in the notice. This is one more reason to discuss not only the principal, but also the soundness of the announced surcharges.

If disagreement remains after the authority's reply to your observations, several routes stay open. You can request a hierarchical review with the auditor's superior, then with the departmental interlocutor. After the tax is collected, a contentious claim may be filed. Each of these stages follows its own rules, which should be examined case by case with suitable legal support.

Adversarial procedure or automatic taxation#

The distinction is decisive. Under the adversarial reassessment procedure, you benefit from the 30-day deadline and the 30-day extension, and the authority must reply to your observations. Under automatic taxation, this framework does not apply in the same way: the 30-day extension does not apply. Identifying the procedure on first reading avoids building your strategy on rights you do not have.

Desk audit or accounting verification#

The reassessment notice may follow a desk audit, conducted from the authority's offices, or an accounting verification, more thorough and usually carried out at the company. The response deadline and the adversarial nature of the procedure follow the same principles, but the volume of documents at stake and the preparation required differ markedly. An accounting verification calls for a more documented response, often built with the accountant who handles the file.

A company receives a reassessment notice covering several heads: a fraction of deducted VAT, an expense deemed unjustified, and a director's remuneration point. The director, busy, files the letter away meaning to come back to it. Three weeks pass. Contacted late, the firm finds that only one of the three heads is seriously contestable, but that only a few days remain. An extension request, sent within the deadline, would have offered an extra month to gather the documents. The useful reflex fits in one sentence: forward the notice to the firm on the day it is received.

• The response deadline is 30 days, extendable by 30 days under the adversarial procedure, on simple request within the initial period.
• No response amounts to tacit acceptance of the proposed adjustments.
• The notice interrupts the limitation period up to the amounts notified.
• The 30-day extension does not apply under the automatic taxation procedure.
• Responding point by point, with documents, is more effective than a contest of principle.
• Late-payment interest of 0.20% per month applies, and surcharges may be added depending on the breaches.