French VAT Audit: What to Do When DGFiP Contacts You

Download or scan the complete document immediately. Keep every page, attachment, delivery record, envelope and secure-message header. An email notification is not enough: it may omit the document title, legal basis, controlled periods, requested format or date from which a time limit runs.

Record the addressee exactly. A group name, Amazon account label or fiscal-representative reference is not a legal entity. Match the notice to the company name, French VAT number, SIREN where applicable, registration address and current representative or agent before anyone releases records.

Create an incident log with one owner, one document index and one version of each answer. Our French VAT audit support service can structure the evidence and draft response after the procedure and authority contact have been confirmed.

BOFiP distinguishes a desk review from external audit procedures. A formal accounting examination is conducted from the authority's office using the accounting file; a verification of accounts normally examines the business accounting more broadly and may be conducted on site or under an authorised alternative arrangement. The audit charter applies to the formal procedures it names, not automatically to every request for explanations.

Copy the issuing office, officer, postal and secure-message references, phone number, legal provisions, taxes, periods, questions, requested format and date into a control sheet. Add who received the document, when and by which channel. Preserve the evidence rather than relying on a manually entered date.

Formal audit notices must identify the years under review and state the possibility of assistance by an adviser. The BOFiP notice guidance also describes the written advance notice used for an accounting verification or examination. Compare those requirements with the document received, but do not declare a notice invalid from a checklist alone; procedural analysis depends on the full file.

Tell the current fiscal representative, tax agent, accountant and data owners which communications may be sent and who approves them. Stop parallel replies. Two plausible answers with different numbers create a new reconciliation problem.

For an accounting examination, the 21 January 2026 BOFiP guidance states that the file of accounting entries must be transmitted in the prescribed electronic form within 15 clear days following receipt of the notice. It explains that neither the receipt day nor the sending day is counted. The notice also describes the secure delivery route.

Validate the FEC before transmission: entity, exercises, opening and closing, mandatory fields, journal continuity, dates, debit-credit balance, character encoding and agreement to the final accounts. Preserve the exact transmitted file, hash or version identifier, delivery receipt and any compliance report.

BOFiP states that failure to transmit within the period, refusal, or a non-compliant file after a conformity request can produce a €5,000 fine, cancellation of the accounting examination and possible opening of an accounting verification. This is why the FEC deadline must not be hidden inside the wider VAT-document request.

A persuasive response is not the largest possible document dump. Start with a period matrix showing the reported amount, source amount, explained difference and evidence reference. Keep the factual bridge separate from the tax interpretation so that a corrected number does not require rewriting the whole position.

Use the French CA3 return guide to identify the reported lines, then reconcile the legal supplier and transaction route before assigning marketplace, stock or import data.

Answer in the same sequence as the authority's questions. For each point, state the confirmed fact, amount, tax treatment, evidence references and any unresolved item. Distinguish what the record proves from what the business believes happened. If evidence is unavailable, describe the gap and recovery action without inventing a substitute.

Use a cover letter, question-by-question response, reconciliation schedules and numbered appendices. Redact unrelated personal or commercially sensitive information only after checking that the redaction does not remove evidence requested by the authority. Preserve the final package and proof of submission.

Do not let a marketplace tax report replace the entity's accounting and VAT analysis. Our guide to marketplace-collected VAT and seller registrations explains why platform collection can coexist with seller imports, stock transfers and direct transactions.

Finding an error does not mean that an immediate unreferenced corrective CA3 is the right first action. Confirm the periods, amounts, cause, downstream credits, payments and procedure already opened. A correction that disagrees with the response schedule can make the file harder to understand.

DGFiP's right-to-error guidance covers good-faith inaccuracies or omissions in returns filed on time and excludes late filing, late payment and deliberate errors. It says regularisation can remain possible during an audit, with different interest treatment after the audit begins. Formal in-audit regularisation has its own conditions and timing, including action before a proposed adjustment in the situations described by the authority.

Record the selected route in writing: return to correct, legal entity, periods, tax and interest, payment, authority contact and effect on the open questions. Do not advertise a penalty reduction as guaranteed; eligibility depends on the facts and procedure.

A proposed adjustment is not just another document request. Article R*57-1 states that it identifies the nature and reasons for the proposed adjustment and invites acceptance or observations within 30 days from receipt. Article L57 requires the proposal to be reasoned so the taxpayer can respond and provides a further 30 days when the taxpayer's request reaches the authority before the initial period expires.

Verify that this adversarial-procedure rule applies to the document received and calculate the period from delivery evidence. If an extension is available and needed, request it in a traceable form before the initial deadline; do not assume silence, a phone call or a meeting invitation extends anything.

Build a response matrix with one row for each factual finding, VAT amount, legal ground, interest and penalty. Mark agree, partly agree or contest, then state the alternative amount and evidence. A general statement that the business acted in good faith does not reconcile the tax base.

DGFiP describes hierarchical review routes during a formal audit and after the authority's response to the taxpayer's observations in cases of continuing disagreement. The named persons and routes appear on the audit notice. The availability, order and time limit depend on the stage and procedure.

The authority expressly states that a hierarchical review request during the audit does not stop the audit work. Continue answering operative requests and protecting deadlines while a review is considered. Keep the disagreement schedule separate from the evidence-delivery schedule.

After every submission or meeting, issue an internal note recording what was sent, what was discussed, what remains open and the next date. The file is not closed until the authority communicates the outcome and all related return, payment, correction or appeal actions are recorded.

DGFiP asks a foreign seller why third-party marketplace data exceeds the sales shown on two French CA3 returns. The seller has original order files, corrected marketplace reports, direct website sales and one refund batch posted in the following month.

The team first classifies the request and records its date. It builds an order-level bridge separating Amazon deemed-supplier sales, seller sales, cancellations, refunds and direct sales. It then maps the seller amounts to each CA3 version, payment and accounting entry and numbers the supporting reports.

The response explains the timing difference and identifies one genuine seller-side omission for separate correction review. Sending only the latest marketplace report would not show why the third-party total and French taxable turnover differ. This is an illustration, not a client case or a prediction of DGFiP's conclusion.

Complete this control before the first substantive reply. Add procedure-specific steps from the notice and adviser review rather than treating the checklist as legal advice.