• Tax audit procedures
• What is a personnal exam on individual tax position (“ESFP”)?
• What is an account audit?
• What is a tax audit on documentary evidence?
• What is a contradictory assessment of additional tax?
• What is an estimated assessment procedure?
• What is the tax prescription?
• What are the prescription delays?
• How long is a tax audit?
• I’m a director or a sharelholder of a company subject to tax adjustments: What are my risks?
• When do I have to pay the tax adjustments?
• What is the tax authority’s communication right?
• What is an irregular management action?
• What is law abuse? (art. L 64 du LPF)
• What are the tax authority information means and methods?
• What is the delay to bring an action to court?

The contradictory assessment of additional tax procedure is applied in all cases where the taxpayer is in conformity with his declaration obligations. The main features of this procedure are a debate between the taxpayer and the tax authorities: proposition of tax adjustments, faculty for the taxpayer to present his observations, and obligation for the tax authority to inform the taxpayer of the action to be taken.

Guarantees

I. The taxpayer may be assisted by an adviser when disscussing the proposed tax adjstusments.

II. The proposed tax adjustments must be fully explained so that the taxpayer has full knowledge of the facts when presenting his arguments and his eventual agreeement. Lack of explanation may invalidate the procedure.

III. The taxpayer has the right to appeal to the controller’s superior (principal or division inspector and area interlocutor) and to request the intervention of the direct incomes and value added tax comission.

IV. The tax authority bears the burden of proof.