The law on tax evasion and serious economic and financial crime, entered into force on 8 December, 2013, extended the limitation period in case of request for international administrative assistance (article L 188 A of the FTPB). The time period during which lack of taxation or insufficient taxation can be adjusted expires now at the end of the year following the one of reception of the answer from the foreign authority (as before) or on 31 December of the third year following the one during which the initial limitation period expired (instead of 31 December of the fifth year following the one for which taxation was due). Moreover, the scope of the provision is extended: while it applied to information request concerning transactions with associated enterprises covered by article 57 of the FTC (transfer pricing) or establishments or subsidiaries benefiting from a privileged tax regime covered by article 209 B of the FTC (CFC rules), the revised text now concerns all information requests relating to the taxpayer.

These provisions apply to requests made within limitation periods expiring as from 8 December, 2013.