The French Ministry of Finance has released welcome initiatives comprising a list of aggressive tax structures, ten commitments for ways of working upon commencement of an audit, appointment of a national committee of experts in complex cases, and creating a R&D tax credit advisory board to provide consultation services to the taxpayer.
A link to PwC’s Tax Insights summary is provided for reference:
Click to access pwc-france-mof-transparency-measures.pdf
10 Audit commitments:
- Initial meeting to inform taxpayer of documents to be requested
- Ways of working in the tax audit
- First meeting devoted to understanding the business
- Milestone meetings
- Indicating the main audit objectives
- Taking consistent positions of similar issues in the same industry
- Meeting deadlines
- Providing a recourse process with access to auditor’s superior
- Maintaining confidentiality and tax secrecy as imposed by the law
- Identifying an individual within FTA for post-audit support procedures
This is a very welcome initiative that will provide win-win opportunities for audits and information requested. Additionally, this process serves as a Best Practices memorandum of understanding that should be discussed with auditors from other jurisdictions.
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