The tax authorities cannot reassess a tax indefinitely. They have a limited period to do so, laid down by the French Tax Procedure Code (LPF): the reassessment period, often called the limitation period. Once this period has expired, the tax for the year concerned can in principle no longer be adjusted, and a tax reassessment notified too late may be annulled.
This article presents in plain terms the reassessment periods for the main taxes, the events that interrupt or extend those periods, and special cases, in particular undeclared foreign accounts. As these rules are technical, how they apply to a given situation generally deserves to be checked with a lawyer.
In brief
- For income tax, corporate tax and VAT, the reassessment period in principle expires on 31 December of the third year following the year for which the tax is due.
- Notification of a proposed reassessment in principle interrupts this period.
- The period is extended to ten years in certain cases: undisclosed activity, undeclared accounts or life insurance contracts held abroad, subject to exceptions.
- For inheritance and gift tax and for IFI, the period is in principle three or six years depending on whether the return sufficiently revealed the tax due.
- Property taxes and the housing tax on second homes can in principle be adjusted until the end of the year following the tax year.
Contents
What is the reassessment period?
The reassessment period is the period during which the tax authorities can correct omissions, shortfalls or errors in taxation. Its length depends on the tax concerned, and its starting point is generally the year for which the tax is due.
It differs from the collection period, which sets the period during which the tax authorities can demand payment of a tax already assessed, and from the claim period available to the taxpayer to challenge their taxes (see how to challenge my taxes).
The standard periods
The table below summarises the standard reassessment periods for the main taxes:
| Tax | Reassessment period in principle | Provision |
|---|---|---|
| Income tax and corporate tax | Until 31 December of the third year following the year for which the tax is due | Article L169 of the LPF |
| VAT | Until 31 December of the third year following the year in which the tax became chargeable | Article L176 of the LPF |
| Inheritance and gift tax, IFI | Three years if the tax due was sufficiently revealed by the return or deed; otherwise six years | Articles L180 and L186 of the LPF |
| Property taxes, housing tax (second homes) | Until the end of the year following the year for which the tax is due | Article L173 of the LPF |
| Business property contribution (CFE) and CVAE | Until the end of the third year following the year for which the tax is due | Article L174 of the LPF |
| Tax fines | Until the end of the fourth year following the year of the offence | Article L188 of the LPF |
An example
Income received in 2023 was declared in the spring of 2024. The corresponding income tax can in principle be adjusted until 31 December 2026. From 1 January 2027, the year 2023 is in principle time-barred, unless an extension or special period applies.
Interruption of the period
Notification of a proposed reassessment in principle interrupts the reassessment period: the tax authorities then have a new period of the same length to assess the tax. The date taken into account is in principle that of receipt of the letter, generally sent by registered post with acknowledgement of receipt. A proposal notified after the period has expired is one of the irregularities presented in the article having your tax audit annulled: the 5 points to check.
Extended and special periods
The law provides for longer periods in several situations, in particular:
- undisclosed activity: where an activity has not been declared and has not been brought to the attention of the tax authorities, the period is in principle extended to ten years;
- undeclared accounts, life insurance contracts or trusts held abroad: the reassessment period for income tax is in principle extended to ten years, except where the total balance of the accounts did not exceed €50,000 during the year (see the article on limitation periods for undeclared foreign accounts);
- omissions revealed by court proceedings or by a claim, which can in principle be corrected until the end of the year following the decision, within a limit of ten years;
- the filing of a complaint for tax fraud, which in principle extends the period by two years;
- a request for information sent by the tax authorities to another State, which may extend the period within certain limits.
For inheritance and gift tax and for IFI, a ten-year period may also apply in certain cases linked to assets or accounts held abroad.
Local taxes
For property taxes and the housing tax, which now remains mainly for second homes since its abolition for main residences, the right of reassessment in principle runs until the end of the year following the year for which the tax is due: a 2026 property tax can in principle be adjusted until 31 December 2027. Where a new building or a change in structure or use has not been declared, special rules nevertheless allow taxes to be adjusted over a longer period (Article 1508 of the CGI).
For the territorial economic contribution, made up of the business property contribution (CFE) and the business value-added contribution (CVAE), the reassessment period in principle runs until the end of the third year following the tax year, subject to the extensions provided for by law, in particular in the event of fraud.
FAQ
Until when can my income tax be reassessed?
In principle until 31 December of the third year following the income year: 2023 income can in principle be adjusted until 31 December 2026. This period may be longer in some cases, for example for an undeclared foreign account.
Is a proposed reassessment received on 2 January valid?
If it concerns a year whose reassessment period expired on the previous 31 December, it is in principle late, unless a special period or extension applies. The date taken into account is in principle that of receipt of the letter; a precise check of the dates is useful.
Is the reassessment period the same for all taxes?
No: it varies according to the tax, from the end of the year following the tax year for property taxes to three years for income tax, or even six or ten years in some cases.
Does the reassessment period apply to fines?
Tax fines are subject to their own period, which in principle expires at the end of the fourth year following the year of the offence. This is the case, for example, of the fine for an undeclared foreign account.
