Utilisation par l'administration fiscale de renseignements obtenus auprès d'administrations étrangères
Auteur | Legal News |
Dans le cadre des contrôles d'entreprises françaises, l'administration fiscale est amenée à solliciter des renseignements auprès des administrations fiscales étrangères. Ces procédures d'échange d'information sont prévues par les conventions fiscales bilatérales qui instituent souvent une obligation de confidentialité stricte des renseignements transmis. En effet, ces renseignements ne peuvent être transmis, outre l'administration, qu'aux juridictions instruisant l'affaire. Le contribuable se trouve donc dans l'incapacité de critiquer efficacement les pièces qui fondent son redressement. Dans un arrêt en date du 4 juin 2008, le Conseil d'Etat revient sur cette difficulté. Pour la Haute juridiction administrative, les juges du fond ne pouvaient, sans porter atteinte au caractère contradictoire de la procédure juridictionnelle, se fonder sur des informations qui n'avaient pas été communiquées aux contribuables, même si le secret résultant des seules stipulations de la convention fiscale bilatérale, s'opposait à la divulgation au contribuable des...
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