In France, tax audits are not carried out on the spur of the moment. Behind every audit notice, every summons or request for documents lies a powerful, hierarchical and formidably efficient administrative organisation. The Directorate-General for Public Finances (DGFiP), the executive arm of the Ministry of Finance, employs more than 10,000 staff dedicated to audits, 5,000 of whom specialise in external audits.

This system, which is often little known to taxpayers, follows a clear logic: to categorise cases according to their size, complexity and sensitivity, in order to target the most significant tax risks. As taxation becomes increasingly internationalised and tax fraud moves online, the French tax authorities are strengthening their structures, refining their tools and adapting their strategy.

For both businesses and individuals, understanding how this organisation works is essential if they are to plan ahead, protect their interests and engage effectively with the authorities.

The DGFiP: the driving force behind tax audits

The DGFiP, established in 2008, is the linchpin of the French tax system. It is responsible both for the day-to-day administration of taxation (collection, enforcement and dealing with the public) and its regulatory function: verifying the accuracy of tax returns and penalising tax fraud.

Its approach to control is based on a three-pronged approach:

1. A centralised body at Bercy, which sets strategic priorities;

2. Specialised national units, focusing on complex cases (multinational companies, high-net-worth individuals, international fraud);

3. Regional and inter-regional teams, responsible for local inspections.

In 2024, the DGFiP confirmed the upward trend in tax audit results, reaching a total of €16.7 billion in notified duties and penalties, which is €1.5 billion more than in 2023 (+10 %). In detail, external audits – carried out on-site – accounted for €9.3 billion, an increase of +12 %, whilst documentary audits generated €7.4 billion, up by nearly +7 %. Even more significantly, actual recoveries totalled €11.4 billion, which is approximately €800 million more than the previous year. These record figures can be attributed to the rise of data mining and artificial intelligence, which guided more than 56 % of audits targeting businesses in 2024.

Three levels of control: local, inter-regional and national

The allocation of a case to a department depends on several criteria: turnover, type of business, geographical location, and also the nature of the tax risk identified.

The departmental directorates (DDFIP / DRFIP)

They primarily audit SMEs and micro-enterprises. Their audit teams deal with businesses with a turnover of less than 1.5 million euros, as well as private individuals (personal tax audits – ESFP). These teams also carry out targeted thematic audits (VAT, income tax, registration duties).

The Interregional Tax Inspection Directorates (DIRCOFI)

They take over from medium-sized enterprises, whose turnover is between 1.5 million and 152.4 million euros (sales), or 76.2 million (services). They have better-resourced teams, capable of handling more complex cases, often involving regional groups or cross-border flows.

Specialised national directorates

They focus their expertise on the most sensitive issues:

• DVNI (Directorate for National and International Audits): large companies and multinationals exceeding the €152.4 million threshold. This is the elite of tax inspection, tackling transfer pricing, intra-group financing and international arrangements;

• DNVSF (National Directorate for the Verification of Tax Situations): audits of high-net-worth individuals (income > €762,000 or assets > €6.9 million). Tax audits of high-net-worth individuals are carried out by its specialist teams;

• DNEF (National Directorate for Tax Investigations): tax intelligence service; investigates complex fraud, VAT carousels and covert activities;

• SFP (Tax Audit Services for High-Net-Worth Individuals): local units specialising in high net worth individuals, often based in major cities (Paris, Lyon, Bordeaux, the Côte d’Azur).

Specialised units and support services

In addition to the directorates, the administration relies on specialist units:

• Control and Investigation Brigades (BCR): identify covert activities, cross-check information with TRACFIN, and carry out field investigations;

• Heritage task forces: focus on the transfer of heritage, property capital gains and financial capital gains;

• ‘Income and Assets’ units: provide support for individuals in complex situations (international income, crypto-assets, trusts).

The tax police, established in 2019 and recently strengthened, complements this system. Its role is to conduct criminal investigations into serious cases of tax fraud, working in direct collaboration with the public prosecutor’s office.

The digital revolution: data mining and artificial intelligence

Since 2014, the DGFiP has been using the GALAXIE platform, which centralises and cross-references a vast amount of data:

• tax returns,

• bank records,

• property transactions (Fiji-based),

• customs information,

• data derived from international automatic exchanges (CRS, FATCA, DAC6).

In 2021, 44.1 % of audit plans were generated through data mining. The DGFiP’s aim is to exceed 50 %, using AI and machine learning.

The algorithms assign a risk score to taxpayers: accounting inconsistencies, abnormal profit margins, flows to tax havens, but also ‘weak signals’ (a disproportionate lifestyle, heavy use of crypto-assets).

This change marks a turning point: tax audits are no longer triggered by an auditor’s intuition, but by a systematic algorithmic selection.

Audit priorities: businesses, private individuals, sensitive sectors

Every year, Bercy publishes its priorities. These reflect a clear strategy: to target the behaviours that place the greatest burden on public finances.

• VAT fraud: a top priority (estimated loss of over €10 billion a year). VAT carousels are tracked down by the DNEF, often through international cooperation;

• Multinationals and transfer pricing: DVNI is at the forefront, with several billion in tax adjustments each year;

• High-net-worth individuals: The DNVSF and SFP are targeting abusive tax exile, the use of trusts and changes of residence;

• Crypto-assets: a new focus in recent years. Platforms are required to report transactions, and unreported wallets are tracked using algorithmic cross-referencing.

• High-risk sectors: construction, catering, retail – sectors often associated with cash fraud.

Staff numbers and announced recruitment drive

The Court of Auditors recently highlighted the downward trend in staff numbers at the DGFiP, as well as their restructuring towards greater specialisation.

• Around 10,000 staff are assigned to tax inspection, including 5,000 external auditors;

• The government has announced the recruitment of 1,500 additional officers by 2027, with the focus on strengthening specialist units;

• The number of staff in the tax police has been doubled to strengthen the criminal enforcement aspect of inspections.

Questionable effectiveness: criticisms and challenges

Whilst the organisation is sophisticated, its effectiveness is regularly debated.

• Results of the audit: €16.7 billion recovered in 2024; however, when compared with the ‘tax gap’ (the difference between tax due and tax collected), estimated at between €60 billion and €80 billion, the impact may seem limited;

• Complexity: the large number of agencies (DVNI, DNVSF, DIRCOFI, BCR) can make things confusing for taxpayers;

• Reputational risk: the focus on high-net-worth individuals sometimes fuels the perception that they are being singled out for symbolic reasons.

The Court of Auditors emphasises two priorities:

1. Make better use of the big data that is already available;

2. Improve the monitoring of audits following the rectification phase (ensuring that the amounts notified are actually recovered).

Practical implications for taxpayers

For a business leader, an investor or a high-net-worth individual, understanding how the DGFiP is organised enables them to plan ahead more effectively:

• An SME will be a priority target for local enforcement teams or a DIRCOFI.

• A medium-sized enterprise or multinational will be audited by the DVNI, with the highest standards of documentation required (DVNI teams specialise by sector of activity);

• A private individual of means will be registered almost always with the DNVSF or the SFP;

• Trigger signals now stem more from algorithms than from reports or chance;

This mapping exercise helps to draw up a tailored defence strategy: enhanced documentation, anticipating the risks of reclassification, and preventive audits.

Conclusion: a tax system that is both centralised and highly specialised

The organisation of tax audits in France reflects the nature of the State: centralised, hierarchical, yet constantly evolving. From its field teams to its elite national directorates, the DGFiP operates a sophisticated system, capable of targeting risks with increasing precision thanks to digital tools.

For taxpayers, the implication is clear: an audit is no longer a remote possibility, but a calculated probability. Planning ahead, keeping records and seeking professional advice are no longer a matter of convenience, but a necessity.

At Qualifisc, we support businesses and high-net-worth individuals at every stage of the tax audit, from preventative audits to defence in the event of a tax reassessment.