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How multinationals can prepare their French subsidiaries for tax raids

15 November 2012

Joe Dalton

A worrying trend is emerging for taxpayers in France, because the tax authorities are increasingly targeting foreign multinationals with French subsidiaries in tax raids.

After Google's Paris headquarters were recently raided by the authorities, and the Paris Court of Appeals validated the investigation, companies must prepare themselves if they want to uphold their rights and minimise the intrusion.

The Paris Court of Appeals ruled, in the case of Google Ireland, Google France v. Administration Fiscale last month, that a tax raid on Google France's Paris headquarters was legal.

Tax raids, which are different to tax audits, and require a warrant obtained from a judge before the authorities can proceed, were deemed to be in compliance with Article L-16-B of the French tax procedure code.

Alain Recoules, of Arsene Taxand, has been present at several of his client's offices during such raids, and said many companies can be ill-prepared for them.

"The tax authorities do not have to give any notice of the raid and will arrive at the taxpayer's premises early...



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