French get tough of tax evasion

"The Loi de Finances Rectificative for 2011 published on 28th December 2011 contains a number of anti-tax evasion changes which can be summarised as follows:

•         An increase of the income and corporation tax "enquiry window" from three to ten years which is more in line with the wealth tax back-assessment period.  This ten year enquiry period concerns all non-French accounts or life insurance policies or bonds including those held in EU or double tax treaty territories.  By exception, this does not concern unreported accounts, the aggregate funds of which do not exceed €50,000.  For instance, the tax year 2009 which would have been closed as at 31st December 2012 will now remain open for enquiries up to 31st December 2019.

•         This new measure also applies to the trustees’ disclosure obligations in respect of trusts with French assets or which have French resident settlors or beneficiaries.

•         Article 58 introduces a new accelerated enquiry procedure which French authorities intend to use as a way to test the goodwill of territories which have signed a Tax Information Exchange Agreement or an Assistance Agreement with France within the last three years.

For any queries on the above, please e-mail french.tax@pkfci.com. "

For any queries on the above, please e-mail french.tax@pkfci.com. "

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