Decree No. 2026-692 abolishes the reduced one-year time limit for withholding tax claims, effective 30 July 2026.
France has restored the standard time limit for withholding tax claims by repealing the reduced one-year deadline through Decree No. 2026-692 of 27 July 2026, published on 29 July and effective from 30 July 2026. The measure implements Conseil d’État Decision No. 500909.
Under the change, claims relating to withholding tax are now subject to the standard deadline under article R. 196-1 of the Livre des procédures fiscales, which is, in principle, 31 December of the second year following the payment of the tax, replacing the previous deadline of 31 December of the year following that in which the tax was withheld.
The decree also repeals and amends several provisions of the Livre des procédures fiscales, including parts of articles R. 196-1, R. 196-1-1 and R. 196-2, as part of a broader effort to align the legislation with the Conseil d’État ruling and simplify the tax claims framework.
