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Recovery period extended to ten years for audits of foreign tax residence

BERGEOT PAOLI ASSOCIÉS

The Finance Act for 2025, passed by the French National Assembly on February 5, introduces a major change in the tax auditing of non-resident taxpayers: the tax authorities’ recovery period is now extended to ten years (plus the current year) in the event of a challenge to the tax domicile abroad.   A measure targeting false declarations of non-residence   This reform responds to a long-identified problem: some taxpayers wrongly declare a tax residence outside France in order to avoid taxation on their income, assets or transfers. However, according to the legislator, proving the fictitious nature of this non-residence requires long and complex investigations, often incompatible with the standard three-year recovery period. The legislator therefore felt that extending the time

Family office and family governance: structuring for the long term

BERGEOT PAOLI ASSOCIÉS

Families with significant wealth, often spread across different countries, face complex management, governance, tax and inheritance challenges. Between family governance, ownership structures and estate planning, every decision taken today influences not only asset management, but also the integrity of wealth for future generations. Whether in a Franco-Swiss or international context, the establishment of a family office, the organization of family governance and the management of intergenerational transfers must be part of a long-term vision, structured and capable of adapting to changing family and fiscal needs.   Family office: a pillar of wealth management   A family office enables a family to centralize and coordinate the management of its wealth across different jurisdictions. Whether for real estate, financial investments, private securities

Recovery period extended to ten years for audits of foreign tax residence

BERGEOT PAOLI ASSOCIÉS

The Finance Act for 2025, passed by the French National Assembly on February 5, introduces a major change in the tax auditing of non-resident taxpayers: the tax authorities’ recovery period is now extended to ten years (plus the current year) in the event of a challenge to the tax domicile abroad.   A measure targeting false declarations of non-residence   This reform responds to a long-identified problem: some taxpayers wrongly declare a tax residence outside France in order to avoid taxation on their income, assets or transfers. However, according to the legislator, proving the fictitious nature of this non-residence requires long and complex investigations, often incompatible with the standard three-year recovery period. The legislator therefore felt that extending the time limit was justified in these situations, following the example of the time limit already applicable to failure to declare foreign bank accounts or capitalization contracts.   Extending the scope of the ten-year recovery period   Until now, the extension of the recovery period to ten years only concerned taxpayers who failed to declare certain assets held abroad, and only income or assets linked to these accounts. The Finance Act for 2025 extends this extended deadline to all situations where the tax authorities dispute the taxpayer’s foreign tax residence, even in the absence of undeclared accounts. The aim of this provision is to make control procedures more secure, and to give the tax authorities greater leeway in complex cases, particularly where evidence is scattered across several countries. Extended scope of application

Family office and family governance: structuring for the long term

BERGEOT PAOLI ASSOCIÉS

Families with significant wealth, often spread across different countries, face complex management, governance, tax and inheritance challenges. Between family governance, ownership structures and estate planning, every decision taken today influences not only asset management, but also the integrity of wealth for future generations. Whether in a Franco-Swiss or international context, the establishment of a family office, the organization of family governance and the management of intergenerational transfers must be part of a long-term vision, structured and capable of adapting to changing family and fiscal needs.   Family office: a pillar of wealth management   A family office enables a family to centralize and coordinate the management of its wealth across different jurisdictions. Whether for real estate, financial investments, private securities management or even philanthropy, setting up a family office is a lever for organization and optimization. In France and Switzerland, families are often confronted with different tax regimes, making cross-border asset management a complex task. A family office can centralize the management of these assets, while guaranteeing tax compliance, particularly in terms of tax declarations, cross-border VAT and inheritance tax. It also offers the possibility of establishing wealth diversification strategies that take into account the tax specificities of each country and the reality of international markets.   Family governance: anticipating to secure the transfer of ownership   Family governance is one of the most effective tools for ensuring consistent management of family assets over the long term. It defines clear rules for asset management, voting rights, roles within the family