Behind the generic term “tax inspection” lie departments with very different cultures, skills and powers. To know them is to better anticipate.
DVNI – Direction des Vérifications Nationales et Internationales (Department of National and International Audits)
The DVNI handles audits of large companies (sales > 152 M€ for industry/commerce, thresholds vary according to sector) and international groups. A single point of contact for complex cases: transfer pricing, cross-border restructuring, optimization schemes. DVNI auditors are specialized by economic sector, giving them real sector expertise. This is also where the heaviest audits in terms of stakes and duration are concentrated.
Specifically on the international front, the DVNI handles cases involving cross-border intra-group flows, questions of executive tax residency, disputed permanent establishments, and optimization schemes using foreign entities. It is also the preferred contact for Mutual Agreement Procedures (MAP) initiated under bilateral tax treaties, in conjunction with the CF3 Office of the Tax Legislation Department.
DIRCOFI – Audit Department
It covers mid-sized companies. Internationally, it is increasingly dealing with cases involving SMEs with foreign subsidiaries or flows, often without the documentary sophistication of large groups, making them a prime target. Issues of “simplified” transfer pricing, misapplied withholding taxes or misinterpreted treaties are frequent at this level.
Local audit brigades (SIE/SIP)
At departmental level, the Business and Individual Tax Departments handle local control. Internationally, they deal with issues such as the tax residence of mobile individuals, undeclared foreign-source income, and assets held abroad (accounts, trusts, offshore wealth structures). With the automatic exchange of information (Common Reporting Standard or CRS), their detection capacity has been considerably strengthened in recent years.
DNEF – Direction Nationale des Enquêtes Fiscales (National Tax Investigation Department)
The DNEF has extensive investigative powers, including the right of inquiry, house searches (tax searches on judicial authorization), and a tax intelligence role. Internationally, it is at the heart of the fight against complex tax fraud: it exploits data from automatic exchanges, whistleblowers (LuxLeaks, Panama Papers, Pandora Papers), and requests for international administrative assistance. It works in liaison with foreign financial intelligence units and TRACFIN.
DNVSF – Direction Nationale des Vérifications de Situations Fiscales (National Directorate for Tax Audits)
Specializing in large fortunes, she is particularly active in cases of disputed tax residency (taxpayers who have left France, for example, but whose actual residence seems questionable). She also handles exit tax cases (article 167 bis CGI), foreign wealth structures deemed transparent (trusts, foundations), and income capitalized in offshore entities. It is the natural point of contact for complex cross-border cases involving individuals with significant assets.
CF3 Office – The conventional dimension
Less visible because it is not operational in terms of control, the DLF’s CF3 Office plays a central role in international litigation: it investigates Mutual Agreement Procedures (MAP), negotiates Advance Pricing Agreements (APA), and issues French positions on the interpretation of tax treaties. For practitioners, it is a key contact in cases of double taxation or disputed treaty qualification.
Litigation: DRFiP and the administrative and civil courts
Once the tax reassessment has been notified and upheld, a prior complaint is sent to the issuing department, after which, in the event of rejection, only the contentious route remains. In the event of rejection, the only remaining option is to take the matter to the appropriate court: often an administrative court, except in the case of disputes concerning registration duties and the IFI, for which the courts have jurisdiction. International cases are even more complex: the relationship between domestic law and the treaty, the question of abuse of rights or fraud, and sometimes parallel recourse to a MAP, whose relationship with domestic legal proceedings remains delicate and little defined in practice.
Things to remember :
In international matters, the defense strategy begins long before an audit notice is received. The identification of the appropriate department, the quality of preventive documentation (particularly with regard to transfer pricing), and knowledge of the conventional mechanisms available are decisive levers that are often under-exploited for lack of foresight.
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