Tax · France
Proposition de rectification — thirty days that decide it
This is the document that opens the contradictory part of a French tax adjustment, and closes it. Reply inside thirty days and the administration must deal with what you say; say nothing and the rectifications are treated as accepted.
How serious: enforcement closeAlso called: imprimé 2120, imprimé 3924, redressement fiscal, proposition de redressement
The proposition sets out what the administration intends to change, for which taxes and which years, and why. It is sent under article L57 of the Livre des procédures fiscales, on a form numbered 2120 or 3924.
Article R*57-1 gives thirty days from receipt to send acceptance or observations, and adds thirty more on a request that reaches the administration before the first period expires. That extension is automatic when it is asked for in time.
Silence is not neutral here. Where no reply arrives inside the period, the taxpayer is treated as having tacitly accepted the rectifications, and the contradictory procedure ends on the same footing as an acceptance in writing.
Who sends it
The Direction générale des finances publiques — the service des impôts des particuliers or des entreprises, or the control brigade, that examined the file.
A form numbered 2120 or 3924 headed 'proposition de rectification', citing article L. 57 of the Livre des procédures fiscales; the taxes and years concerned; the reasons for each rectification; the new bases and the penalties envisaged; and an invitation to reply within thirty days.
The deadline
30 days from receipt, extended by 30 more on a request made inside them
Thirty days from receiving the proposition, extended by thirty more where the request for the extension reaches the administration before the first period expires (Livre des procédures fiscales, art. R*57-1). The extension applies whatever kind of audit produced the proposition.
If you do nothing
The rectifications are treated as tacitly accepted where nothing arrives within the thirty days — or the sixty, where the extension was granted. Tacit acceptance ends the contradictory part of the procedure and has the same effect as accepting in writing, and a reply arriving after the period is in principle no longer taken into account (BOI-CF-IOR-10-50-20).
Compute your date
The rule above is what the law sets. Put in the dates on your own letter and it becomes a date.
How it escalates
- 01The rectifications are treated as tacitly accepted and the contradictory procedure ends (BOI-CF-IOR-10-50-20).
- 02A reply arriving after the thirty days — or the sixty with the extension — is in principle no longer considered.
- 03The taxes and penalties proposed go into recovery, and an avis de mise en recouvrement follows.
- 04What remains afterwards is the ordinary réclamation contentieuse, a different procedure with its own deadlines.
How to respond
Below is the procedure only: what the reply has to identify, where it goes, and by when. What position to take on each rectification is a matter for an accountant or a lawyer.
Response types
- Send observationsObservations in reply to the proposition de rectification · Livre des procédures fiscales, articles L57 and R*57-1
- Ask for thirty more daysRequest for the thirty-day extension · Livre des procédures fiscales, article R*57-1
- Accept, in whole or in partExpress acceptance, in whole or in part · Livre des procédures fiscales, article L57
Where and how
- A lettre recommandée avec avis de réception to the service that signed the proposition.
- The messagerie sécurisée in your space on impots.gouv.fr, which records the date.
- Ordinary post, which proves nothing about the date.
- The counter of the service that signed it — ask for a dated stamp on your copy.
What to attach
- Copies of the documents relied on, listed and numbered.
- A copy of the proposition de rectification.
- The request for the extension, where it was made — with its own proof of date.
What makes it count
The observations must reach the service within thirty days of your receiving the proposition — sixty where the extension was requested in time. Silence inside the period is tacit acceptance, and a reply after it is in principle not taken into account.
Common questions
Is the extension automatic?
It is granted automatically where the request reached the administration before the first thirty days expired, whatever kind of audit produced the proposition. Asking after the period has run does not revive it.
Do the thirty days run from the date on the letter?
Article R*57-1 counts them from the receipt of the proposition, not from its date. Keep the envelope or the avis de réception, because the date of receipt is what the period is built on.
What if I reply to only part of it?
Acceptance is tacit on whatever is left unanswered. Partial acceptance is expressly contemplated: the procedure continues on the points answered and ends on the others.
Is a reply that is not really 'observations' enough?
The administration treats a reply that cannot be regarded as observations within the meaning of article L. 57 in the same way as no reply at all. What makes a reply count as observations is a question for an accountant or a lawyer.
Sources
Facts verified against the sources below on 10 September 2026.