Tax audits have always been a balancing act: on the one hand, the government’s sovereign duty to protect the tax base and combat fraud; on the other, the necessary relationship of trust with the taxpayer, which lies at the heart of the 2018 ESSOC Act and the ‘relationship of trust’ championed by the DGFiP. In 2025, this tension is more acute than ever. Digitalisation, artificial intelligence and the automation of criminal proceedings are fundamentally transforming tax audits. As a result, businesses and high-net-worth individuals are facing a tax authority that is both more accessible and more relentless.

A modernised but more intrusive public administration

Since 2018, the ESSOC Act has laid the foundations for a ‘right to make mistakes’, intended to foster a culture of learning and support. In practical terms, the DGFiP is developing tools to ensure compliance at an early stage: information campaigns, reminder letters and encouragement to rectify errors voluntarily.

At the same time, however, enforcement measures are being stepped up: the widespread implementation of the Accounting Entries Register (FEC), large-scale data analysis via the GALAXIE platform, and automatic cross-checking with information obtained through international data exchanges (CRS, DAC6, FATCA). The figures speak for themselves: in 2024, audits yielded nearly 17 billion euros, an all-time record.

Support for SMEs, stricter measures for large organisations

The DGFiP adopts a differentiated approach. SMEs are offered more advice and support, with audits that are sometimes designed to educate and more frequent discretionary waivers.
By contrast, for large groups and high-net-worth taxpayers, the approach is more punitive. The tax authorities prioritise high-stakes cases: transfer pricing, abuse of rights, cross-border flows and sophisticated wealth structures.

Thus, the ‘right to make mistakes’ is not a free pass: it is intended for small organisations acting in good faith, not for highly optimised schemes.

The increasing automation of criminal proceedings

Since the abolition of the ‘Bercy lock’, the most serious cases are now systematically referred to the public prosecutor’s office. The thresholds are clear: for amounts exceeding €100,000 in evaded tax (€50,000 in the case of repeat offences or aggravating circumstances), the DGFiP refers the matter to the courts.
This automatic referral represents a radical change: a major tax audit no longer ends merely with a financial adjustment, but may lead to a criminal investigation. For company directors, the risk of being held personally liable is now very real.

How should we prepare for 2025?

In this context, planning ahead is more essential than ever. This involves:

• To regularly check that the company accounts, tax returns and consolidated accounts are consistent.

• To systematically document intra-group transactions and significant asset flows.

• To put in place internal procedures to respond promptly to a request from the administration.

• Planning ahead in terms of communication: a tax audit is also about how the dialogue is perceived and managed.

Legal and tax advice should no longer be viewed as optional cover, but as a governance strategy.

Conclusion

In 2025, tax audits are neither purely educational nor purely punitive. They are both at the same time. Taxpayers acting in good faith have more tools at their disposal to put their affairs in order, but those who deliberately engage in risky schemes face a tax authority that is better equipped, more digitally advanced and more determined.

At Qualifisc, we support business leaders, corporate groups and high-net-worth individuals in safeguarding their operations, preparing for audits and, where necessary, organising their defence.