A tax audit can take several forms, such as a document-based audit, a remote accounting review, or an on-site accounting verification. The on-site audit is conducted in three main stages: before the audit begins, during the exchanges with the auditor, and up to the synthesis meeting and its follow-up. The on-site audit typically starts with the taxpayer receiving a notice of verification sent by registered letter with a request for a receipt (LRAR) to the company's legal representative. This notice includes the specific tax years under review, the taxes involved, and the date of the first meeting. It also reminds the taxpayer of their right to be accompanied by an advisor and outlines the Charter of the rights and obligations of the taxpayer being audited. Before the formal notice is received, the auditor may call the company, but this call does not replace the formal written notice. A system should be set up to ensure that all correspondence from the tax administration, especially the verification notice, is quickly passed to an authorized person. Upon receiving the notice, note the relevant tax years, the taxes involved, and the date of the first meeting. If needed, request a reasonable delay for the first meeting. This date is not fixed, and the auditor may agree to a justified request for a postponement. Call the auditor to propose a new time slot and confirm the agreement by email. Before the first meeting, test the accounting records related to the audit period using the administration's free tool called Test Compta Demat (available at https://www.impots.gouv.fr/test-compta-demat). Prepare explanations and save the positive results to present to the auditor. Prepare a presentation of the company (and the group, if applicable), including its activities, business model, organization, main flows, and significant events. The first meeting is a crucial moment for establishing contact, handing over the accounting records, and presenting the company and its operations. It is also an opportunity to ask the auditor what is motivating the audit, agree on a working method, and set up a preliminary schedule. Hand over the accounting records at the start of the audit and present the company, its activities, and its main events. This initial exchange is the first substantive contact with the auditor and gives the company its first opportunity to make a positive impression. During this meeting, it is also appropriate to ask the auditor if there is a specific issue that triggered the audit, to better prepare for future document requests. Agree on a working method and a schedule. Suggest that the auditor's questions be sent in advance of each meeting to allow time to prepare answers, gather documents, and consult the right people. This helps ensure that responses are more effective and well-prepared, in collaboration with your advisor. Discuss the audit schedule and the general meeting calendar (every 15 days, monthly, etc.), keeping in mind the time limits for submitting documents. The audit duration is not fixed in principle, except for small and medium-sized enterprises (SMEs), which have a maximum of three months under certain conditions. The auditor usually works alone but may be accompanied by specialized agents if the audit requires particular expertise, such as in computerized accounting, transfer pricing, or research tax credits (CIR). In some cases, an expert from the Ministry of Higher Education and Research (MESR) may be involved. The company's advisor, such as a certified accountant or lawyer, may also be present. Designating a single contact person within the company can help coordinate contributions from the certified accountant, operational teams, or specialists, ensuring consistency in responses and avoiding contradictions. Ensure that this person has the authority to represent the company and has a signed mandate from the authorized person. Prepare for each meeting. If possible, arrange a dedicated room for the auditor to work. Request that the auditor's questions be sent in advance. Gather the necessary documents, consult the right contacts, and agree on a regular meeting schedule rather than managing requests on the spot. Hold progress meetings at regular intervals during the audit phase. Answer the auditor's questions precisely and proportionally, never on the spur of the moment. If unsure, delay the response and provide a documented answer; if the question is unclear, ask for clarification. In case of a blockage in the exchanges, contact the team leader. Make every effort to maintain a smooth dialogue with the auditor. If the dialogue proves impossible or permanently difficult, it is possible and sometimes useful to request (in writing) a meeting with the auditor's superior, simply stating the difficulties (without detailing them in the written request). The goal is to unblock the situation and restore communication. Keep control of the schedule and the documents. Track the requests, responses, and documents transmitted, and monitor the time limits for submitting documents. This discipline helps avoid unnecessary or incomplete transmissions, detect residual questions quickly, and identify potential points of disagreement early. The goal is to present the validity of the company's position with supporting documents and explanations. Identify in advance the situations where a legal advisor is appropriate or essential. According to our experience, the legal advisor (tax lawyer) does not always need to be present during meetings with the auditor. They can be useful in advance to review the answers, frame explanations, and identify technical or strategic issues. However, certain situations may require their direct involvement in meetings: discussions on the probative nature of the accounting, verification of an alleged stable establishment, issues related to transfer pricing or CIR, managing the risk of penalties for deliberate non-compliance, arbitration on the appropriateness of a voluntary correction, questioning the appropriateness of a hierarchical appeal request during the audit, and preparing the synthesis meeting, among others. The audit is generally concluded with a synthesis meeting. This meeting is not mandatory, but it is almost always held; it constitutes the last oral exchange before the administration formally presents its position in writing. Prepare for the synthesis meeting by anticipating the points of disagreement. Based on the exchanges during the audit, identify potential points of disagreement and assess their financial implications for the tax years under review, as well as any knock-on effects, such as consequences for open but un-audited years and implications for employee participation. This analysis will help better prepare for the upcoming discussion and prioritize the issues. Make the synthesis meeting a strategic moment. It is the last oral exchange before the formal written formulation of the corrections. If the audit has been well managed, the meeting should not be a surprise: it should allow the identified points to be summarized, their implications discussed, and an initial discussion opened, supported by additional documents, or even more so, particularly in the hypothesis that the auditor might consider the application of penalties. Consider the interest of using the regularization procedure under Article L. 62 of the Book of Tax Procedures (LPF). When errors, inaccuracies, or omissions have indeed been made, this provision allows for regularization during the audit (before receiving a correction proposal) under the condition of good faith, benefiting from a 30% reduction in late interest and the absence of penalties. The verification phase is an exchange phase, the outcome of which is, or is not, corrections. The synthesis meeting does not close the entire procedure. If the administration considers corrections, the company will receive a correction proposal and will have 30 days, extendable to 60 days, to present its observations. The administration will then send its response to the taxpayer's observations (ROC). In case of persistent disagreement, two successive hierarchical appeals will follow, and when the conditions are met, the possible submission to advisory committees; if the corrections are maintained, the administration will then issue a notice of enforcement, before a potential legal dispute. Therefore, everything must be done during the verification phase to make the eventual corrections as limited as possible. Once the corrections are formally written in the correction proposal, it will be significantly more difficult for the auditor to abandon a correction than to maintain it. By Christophe Leclère, associate lawyer & Victoire Gasperini, lawyer / CMS Francis Lefebvre