In 2024, tax auditing in France remains a strategic pillar of public policy, aimed at preserving tax fairness and reinforcing the state’s financial sovereignty. The fight against tax evasion and fraud mobilizes increased resources and leverages ever more advanced technologies. The tax authorities have not only intensified their repressive measures to deter fraud but also strengthened preventive measures.

The updated legal framework, along with new tools for data cross-checking and investigation, illustrates the ongoing effort to adapt control methods to new forms of fraud. This article summarizes major developments in tax auditing for 2024, focusing on measures outlined in the latest Finance Act.

Strategic reinforcement of resources

The fight against tax fraud in 2024 builds on a reinforced approach with increasingly sophisticated technological and human resources. The document appended to the 2024 Finance Act highlights the importance of technologies such as artificial intelligence and data mining, which now play a central role in targeting control operations. By 2022, over 50% of tax audits had been scheduled using these digital methods, and this remains the target in 2024.

The “data lake” established by the Direction Générale des Finances Publiques (DGFiP) integrates data from a variety of sources, both internal (tax returns) and external (digital platforms, social networks). This enhanced capacity for cross-referencing information improves the effectiveness of audits by quickly identifying risky behaviors. Additionally, tools for analyzing unstructured data, such as text and images posted online, enable tax authorities to detect new types of complex and often cross-border fraud.

At the same time, the DGFiP has enhanced its collection processes. One priority in the fight against tax fraud for 2024 is to ensure that debts arising from tax reassessments are effectively recovered. To this end, a stronger synergy has been created between tax inspection services and public accountants to expedite recovery and limit tax losses. This effort is supported by robust legal tools that facilitate the rapid enforcement of tax debts.

Increased judicialization of serious fraud

Facing increasingly sophisticated fraud, particularly in the areas of international taxation and complex arrangements, the tax authorities have strengthened their judicial approach. The 2018 anti-fraud law expanded the administration’s powers to impose sanctions.

In 2024, the transformation of the Service d’Enquêtes Judiciaires des Finances (SEJF) into the Office National Anti-Fraude (ONAF) marks a new phase in this repressive strategy. The tax authorities’ goal is clear: to crack down more severely on serious and intentional fraud in close cooperation with judicial authorities.

The DGFiP’s judicial unit relies on two specialized services: the Brigade Nationale de Répression de la Délinquance Fiscale (BNRDF) and the Service Judiciaire d’Enquêtes Fiscales (SEJF). These units are on the front line in combating organized and transnational fraud, playing a central role in detecting and dismantling sophisticated tax evasion schemes, often concealed by offshore structures. Their work is supported by stronger cooperation with criminal courts, enabling the imposition of legal sanctions ranging from fines to prison sentences.

International fraud and enhanced cooperation

Controlling international tax fraud is a top priority in the DGFiP’s 2024 action plan. Particular attention is paid to cross-border tax avoidance schemes involving shell companies and offshore structures. Cooperation with international bodies, notably the Organization for Economic Cooperation and Development (OECD) and the European Union (EU), has been intensified.

Additionally, the automatic exchange of information between tax authorities, progressively implemented through DAC (Directive on Administrative Cooperation) directives, now facilitates the identification of taxpayers hiding assets abroad. In 2024, tax authorities have focused their efforts on strengthening specialized international tax brigades and improving methods for detecting abusive tax arrangements, particularly in transfer pricing.

Now more than ever, multinational companies need to exercise caution in cross-border tax practices. Using complex structures to artificially reduce tax liabilities exposes companies to severe sanctions, both fiscal (with penalties of up to 80%) and criminal.

Combating VAT and asset fraud

VAT fraud remains a major concern in 2024. The document attached to the Finance Act underlines the crucial role of the Groupe Opérationnel National Anti-Fraude (GONAF) in addressing VAT fraud. This group coordinates actions to combat VAT fraud through national and international investigations. The substantial revenue loss to the state, estimated at several billion euros each year, justifies the reinforcement of investigation and sanctioning resources in this area.

Additionally, the DGFiP is focused on combating wealth-related fraud, often associated with schemes to conceal assets or artificially reduce inheritance tax. The establishment of income/asset control centers (PCRP) at the departmental level has strengthened the response to these challenges, mobilizing specialized local teams equipped with advanced tools to analyze specific tax situations.

The year 2024 marks a decisive turning point in France’s fight against tax fraud. The strengthening of technological resources, increased international cooperation, and the judicialization of serious fraud cases together create a more robust legal and technical arsenal. The use of artificial intelligence and data mining now enables the DGFiP to detect fraud earlier and more effectively, but also requires companies to adapt to these new requirements.

For companies, particularly those with international operations, this new environment calls for heightened vigilance in tax compliance. Adopting transparent tax practices and adhering to international tax rules is essential to avoid tax reassessments and criminal sanctions.

In this evolving context, it is crucial for business leaders to seek expert guidance to anticipate tax audits, correct any discrepancies, and protect against the risk of reassessment.