Taxation: The big comeback of the regularisation desk for foreign assets in 2027

The French government is preparing to reopen a tax regularisation unit in 2027 to encourage taxpayers to voluntarily disclose assets concealed abroad.

Nine years after the Service de Traitement des Déclarations Rectificatives (STDR, the French tax authorities’ former voluntary disclosure unit) closed at the end of 2017, this announcement is part of an overall budget recovery strategy aimed at diversifying public revenue while strengthening tax compliance.

For the taxpayers concerned, this announcement marks the return of a predictable framework, but it also raises a crucial question: should they wait for this desk to open officially, or regularise their situation without delay?

An “STDR 2.0” in a context of total transparency

Between 2013 and 2017, the previous regularisation unit (the STDR) processed more than 50,000 cases, bringing around 32 billion euros in assets back within the tax authorities’ reach and generating 8 billion euros in revenue for the State. At the time, the scheme accompanied the gradual end of banking secrecy.

Planned as part of the budget guidelines for 2027, the future desk will operate in a profoundly transformed ecosystem:

• Automatic exchange of information (AEOI): The tax authorities now receive financial data from foreign banks in bulk.
• Tracking down crypto-assets: With the entry into force of directives such as DAC8, digital asset platforms actively share the identity of their users.
• Artificial intelligence: The tax authorities rely heavily on data mining to cross-check wealth data and detect inconsistencies.

Concealment has therefore become an increasingly risky option.

What will be the scope of the 2027 unit?

While the precise scale of penalties has yet to be set by the government, tax law specialists anticipate a broader scope of action than in the past. The unit is expected to deal with:

• Traditional financial assets: Undeclared bank accounts and life insurance policies held abroad.
• International real estate: Property held outside France, in particular omissions or undervaluations relating to the Impôt sur la Fortune Immobilière (IFI, the French real estate wealth tax).
• Digital currencies: Crypto-asset accounts and wallets held on foreign platforms.

Wait until 2027 or regularise now?

The announcement of this reopening creates a dilemma for taxpayers whose situation is irregular. Two strategies compete:

Option 1: Wait for the desk to open in 2027

• Advantage: The certainty of benefiting from a harmonised, public scale of penalties, potentially lighter than the maximum penalties applicable where the taxpayer is subject to a tax audit.
• Major risk: Time is running out. If the tax authorities initiate an audit, send a formal notice or receive an automatic bank alert before 2027, the taxpayer loses the benefit of the “voluntary” approach. The applicable penalties are then the maximum ones (fixed fines per year of omission, a 40% to 80% surcharge for deliberate default, or even criminal prosecution).

Option 2: Initiate a voluntary disclosure under ordinary law

There is no need to wait until 2027 to put your affairs in order. Regularisation under ordinary law remains possible at any time with the regular tax offices. Although the absence of an official, centralised scale creates some uncertainty as to the reductions granted, starting the process immediately freezes the situation and protects the taxpayer against the risk of an unexpected tax audit.

Conclusion: Essential technical preparation

Whether a taxpayer chooses to take the plunge immediately or to wait until 2027, the watchword among wealth management professionals remains the same: anticipate. Reconstructing the history of accounts sometimes opened several decades ago, documenting the origin of the funds (inheritance, professional income, etc.) and calculating the taxes evaded requires several months of technical work. Preparing your file in advance is the key to acting at the most opportune moment. Bear in mind that, once you receive a formal notice from the tax authorities, you will have 30 days to respond…

Contact our tax lawyers without further delay!