Recently, the Administrative Court of Montreuil issued a decision regarding the statute of limitations for the recovery of tax claims following a collection notice. The statute of limitations for recovery is 4 years, although this may be extended by an additional 2 years when the tax to be collected is due by a taxpayer established in a State that is not a member of the EU, and with which France does not have an agreement relating to mutual assistance for recovery having a similar scope to that provided for by Council Directive 2010/24/EU on assistance in the recovery of tax claims.
In addition, the statute of limitations for recovery of tax claims is separate from the statute of limitations for assessments by the tax authority, which is generally 3 years or 10 years in cases of fraud, undeclared activities, etc.
