Time limit for bringing an action before the tax judge after an implicit rejection of a claim served to tax authorities: reasonable time limit or endless time limit?
The French administrative supreme court (Conseil d’État) has just clarified that the rule of reasonable time limit to bring an action before the administrative court does not apply to tax disputes[1].
·Background
A taxpayer had submitted a contentious claim. Tax authorities implicitly rejected that claim (silence of the authorities beyond...