Bilan 2025 du contrôle fiscal

On 7 April 2026, the French Tax Authorities published their annual report on tax audits carried out in 2025.

Key figures to remember

The Tax Authorities notified €17.1 billion (bn) in tax and penalties to individuals and businesses following a tax audit, an increase of nearly 3% compared with 2024. This overall figure breaks down into two parts. The tax and penalties notified following:

• external tax audits, carried out on site by tax inspectors, amount to around €9.8bn, up 11% since 2022;
• desk audits, carried out “from the office” by tax inspectors, amount to €7.3bn (- 0.9% compared with 2024).

The 2025 tax audit report stresses the particular attention paid to audits of personal wealth since 2023. The results are tangible: +€249 million (m) in amounts notified in respect of personal taxes (income tax, social contributions, registration duties, real estate wealth tax).

Added to these amounts are the results of audits of refunds of tax credits and taxes, which reach €8.4bn, compared with €3.4bn the previous year, an increase of 148%. This rise is, however, explained by the processing of VAT credit refund claims filed by a single company, for a total amount of €4.85bn.

Taking these two components together, tax and penalties notified on the one hand, tax credits and taxes not refunded on the other, the total contribution of tax audits to public finances stands at €25.5bn in 2025, up 27% compared with 2024.

AI at the heart of the Tax Authorities' strategy

The 2025 tax audit report is unambiguous on this point: artificial intelligence (AI) is no longer an experimental tool; it is now at the heart of the Tax Authorities' targeting strategy.

52% of the cases concerning businesses closed by the Tax Authorities and more than 54% of those concerning individuals were thus selected using AI in 2025.

AI - data mining made it possible to collect more than €2.8bn in tax and penalties in 2025, compared with €2.5bn in 2024.

The National Remote Audit Units (PNCD)

Created between 2021 and 2023, the five PNCDs handle straightforward cases involving individuals on the basis of information derived from AI.

In 2025, 29,751 cases were opened, compared with 25,833 in 2024 and 18,190 in 2023. 29,704 cases were closed, with an average reassessment rate of 77% and a total amount of net tax of €84.5m.

In 2024, this organisational model was extended to business taxpayers with the opening of a first PNCD. In 2025, out of 2,307 cases opened, 1,556 cases were closed, generating €6.1m in net tax.

Combating tax fraud

The fight against tax fraud accounts for just over 34% of on-site tax audit cases.

The internationalisation of tax avoidance and fraud schemes has led the Tax Authorities to step up their audit work at international level. This work has resulted in corporate income tax and personal income tax reassessments, two thirds of which relate to transfer pricing.

More avoidance schemes involving low-tax States or territories and more fictitious residences of individuals abroad have also been detected.

As regards investigations, the specialised directorates and departments have stepped up their enforcement action. The National Tax Investigations Directorate (DNEF) carried out:

• 181 tax searches in 2025 (compared with 146 in 2024);
• 700 suspensions of VAT numbers as part of the fight against organised VAT fraud;
• 670 operations conducted by the fraud squads, leading to the collection of €406m in tax and penalties;
• 34% of penalties for bad faith.

In addition, 2,138 cases were referred to the judicial authorities (including 282 complaints for tax fraud) in 2025.

In 2026, the roll-out of electronic invoicing will strengthen the Tax Authorities' capacity for action.

Leniency for taxpayers acting in good faith

In accordance with the ESSOC Law of 10 August 2018, 50.9% of tax audits ended with the taxpayer's acceptance in 2025 (compared with 44.6% in 2024).

At the same time, the tax audit departments are strengthening legal certainty for businesses:

• 2,033 businesses benefited from personalised tax support in 2025, bringing to 6,855 the total number of businesses supported since the scheme was introduced;
• 17 new protocols were signed with groups, bringing the total to 116 partner groups;
• 73 requests for voluntary tax compliance were received in 2025.

The bill on combating social security and tax fraud aims to give the Tax Authorities further powers: better flow of information between departments, heavier penalties for those who facilitate fraud, and greater anonymity for officials exposed during audits.

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