Through communication right, the French tax authorities (FTA) had already the right to obtain documents held by thirds parties in order to establish tax base and to control the tax.
Since December 31st, 2016, the FTA can hear people able to provide useful information for the completion of its duties (Article L10-0 AB du Livre des procédures fiscales). This right can be applied at any time even outside of a tax audit. So, when they investigate into a taxpayer, the FTA may also ask for a hearing with thirds parties (clients, suppliers, employees, ex-employees, service providers and so on). These people are susceptible to provide information on breaches concerning tax fraud and international tax evasion. The breaches relative to transfer pricing rules constitute a new scheme to verify functional analysis given by the taxpayer.
