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On January 1, 2025, France’s Ministry of Economy and Finance implemented major reforms to the tax payment suspension mechanism under the Initial Finance Law (LFI) 2025. These changes aimed to reduce financial strain on businesses and streamline dispute resolution.
Key Reforms:
🔹 Lower Guarantee Requirement – Reduced from 50% to 25% of the disputed tax amount.
🔹 Direct Payments to Treasury – Payments were made to the Deposit and Consignation Fund for security and transparency.
🔹 Full Reimbursement – If a taxpayer won the dispute, the entire 25% guarantee was refunded.
Additional Improvements:
Faster Resolution – A simplified process with single direct payments to the Treasury, speeding up dispute settlements.
Enhanced Protection – Suspension of forced collection measures and protection against third-party notices (ATDs) during disputes.
Flexible Payment Options – Businesses could request staggered payments while retaining legal recourse.
This reform was part of France’s broader effort to modernize tax administration and provide a more business-friendly tax environment.
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