TL;DR: For breaches referred to in Sections I or III of Article 1649 ter D of the CGI and sanctioned under Section XI of Article 1736 of the CGI, the tax fine becomes time-barred at the end of the fourth year following the year in which the infringement was committed.
The applicable rule
You are subject to this limitation period when the fine sanctions a breach of Sections I or III of Article 1649 ter D of the French General Tax Code (CGI). The fixed fine provided for by Section XI of Article 1736 of the CGI may not exceed 50,000 euros.
The limitation period follows from the second paragraph of Article L. 188 of the French Tax Procedure Code (LPF), applicable to tax fines sanctioning infringements of provisions other than those relating to the assessment and collection of tax.
Calculating the limitation period
You must link the limitation period to the year in which the infringement was committed. The limitation period expires at the end of the fourth year following that year.
The breaches concerned
The fixed fine notably applies to breaches of due diligence procedures, as well as to failure to communicate to each seller or service provider the data concerning them, where that data is transferred to the tax authorities.
The application of the fine varies according to the nature of the infringement, up to a limit of 50,000 euros.
A rule that does not extend to all fines
You must not automatically extend this four-year limitation period to all tax fines that may concern a digital platform operator. You must examine the provision of the CGI on which the relevant sanction is based.