Article L 80 M of the LPF: non-compliance with the adversarial principle

In a judgment of March 18, 2020 (Cass. com., March 18, 2020, no. 17-20596, ruling 268 FS-P+B°), the French Supreme Court considers that the principle of adversarial proceedings provided for in Article L 80 M of the Tax Procedure Book is not respected when the taxpayer receives the documents on which the administration bases its decision after the establishment of the statement of offence.

Article published in the Village de la Justice