The provisions of Article 885 D of the French General Tax Code lead to the applicability to the wealth tax of the statutes of limitation linked to inheritances.

Consequently, regarding the audit linked to the qualification as professional of some declared goods, the decennial examination time-limit may apply, as the Tax Authorities will have to make subsequent researches in order to prove the exigibility of the rights possibly left out.

However, the challenging of the validity of some liabilities items duly declared and justified is subject to the shorter examination time-limit (three years), when the wealth tax return, having a net asset superior to the taxation ceiling, has regularly been filed (Rep. Feron, AN April 29, 1996, p. 2318, no. 33258).

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be brought about your specific circumstances.

For additional information contact Claire Acard on 33/(1)/55 61 10 10, Lionel Benant on 33/, Joel Fischer on 33/, or Laurent Borey on 33/(1).55 61 10 10 or enter text search: "ARCHIBALD ANDERSEN Profile".

The members of ARCHIBALD ANDERSEN Association d'Avocats (S.G. Archibald and Arthur Andersen International) are registered with the Hauts-de-Seine Bar and the Lyon Bar.