Current issues

In recent years we have helped many clients become tax compliant when they were holding undeclared foreign assets and wished to regularise matters voluntarily with the tax authorities.

To do so, we filed the relevant information with the Amended Returns Processing Department (Service de Traitement des Déclarations Rectificatives - STDR) in accordance with the Cazeneuve Memo of 21 June 2013, which guarantees consistent treatment of situations and automatic reduction of any penalties that might be imposed on “repentant” taxpayers.

However, as such cases gradually decreased and countries began exchanging bank information, the government repealed the Cazeneuve Memo and the STDR closed on 1 January 2018. Instead of being offered a carrot, non-compliant taxpayers are now threatened with a stick.

We can only recommend that if you haven’t complied with your tax obligations, contact us to explore how you can voluntarily come into compliance. This is obviously preferable to avoiding the issue until the exchange of information between countries leads to a tax audit, which would undoubtedly be followed by criminal proceedings.

We have developed very specialized expertise in regularising foreign assets and are helping more clients than ever obtain the best possible outcomes.