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Tax · France

Saisie administrative à tiers détenteur — no judge, two months

The tax authority did not go to court. It served a seizure on whoever holds money for you — usually your bank — on a title it holds itself. You have two months to bring an opposition, and the money moves anyway while it is examined.

How serious: enforcement closeAlso called: SATD, avis à tiers détenteur, ATD, saisie sur compte par le Trésor

A comptable public seizes sums held for the debtor by a third party — a bank, an employer, a tenant. No judge is involved, because the public accountant acts on its own title.

From the notification runs two months to bring an opposition à poursuites under article L281 of the Livre des procédures fiscales, within the period article R*281-3-1 sets. The opposition goes first to the administration, not to a court.

Four grounds are open: the regularity in form of the act, the amount taking account of payments already made, the exigibility of the sum, and the obligation to pay it. Which one is relied on decides which judge hears the matter afterwards.

Who sends it

A comptable public — the Direction générale des finances publiques for taxes, or another public accounting officer for other public debts.

A notice from a service of the Direction générale des finances publiques headed 'saisie administrative à tiers détenteur', naming the tiers détenteur, the taxes or debts and the periods, the amount seized, and the service to which a contestation is addressed.

The deadline

two months from the notification of the seizure

Two months from the notification of the seizure, under article R*281-3-1 of the Livre des procédures fiscales, applied through article L281. The opposition is addressed first to the service that issued the seizure.

If you do nothing

Nothing pauses. The tiers détenteur must pay the sums over at the latest within thirty days of receiving the seizure, whether or not an opposition has been brought, and after two months without a valid contestation the measure stands.

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

  1. 01The tiers détenteur pays the sums over to the Public Treasury, at the latest within thirty days of receiving the seizure.
  2. 02An opposition brought after two months is out of time (Livre des procédures fiscales, art. R*281-3-1).
  3. 03The debt remains due for anything the seizure did not cover, and a further SATD is possible.
  4. 04Bringing an opposition does not itself suspend the seizure — acting inside the period preserves the argument, it does not release the money.

Your options, procedurally

  • Bring an opposition à poursuites within two months of the notification, to the service named on the notice.
  • Contest the regularity in form of the act.
  • Contest the amount, taking account of payments already made.
  • Contest the exigibility of the sum, or the obligation to pay it.
  • Pay or arrange payment with the comptable public — the seizure is not suspended while anything else is discussed.

How to respond

Below is the procedure only: where the opposition goes, what it must identify, and by when. Which ground fits the facts is a question for an adviser.

Response types

  • Bring an opposition à poursuitesOpposition à poursuites to the comptable public · Livre des procédures fiscales, articles L281, R*281-1 and R*281-3-1
  • Ask what the seizure coversWritten request for the detail of the debts covered by the seizure
  • Ask the comptable public for timeRequest to the comptable public for time to pay

Where and how

  • A lettre recommandée avec avis de réception to the service named on the notice.
  • The messagerie sécurisée in your space on impots.gouv.fr, which records the date.
  • Ordinary post, which proves nothing about the date.
  • The service's telephone number, which brings no opposition.

What to attach

  • A copy of the notice of seizure.
  • Proof of the payments relied on, where the amount is in issue.
  • A copy of any earlier decision or agreement about the debt.
  • A statement of income and outgoings, where time to pay is asked for.

What makes it count

An opposition counts when the service named on the notice receives it, within two months of the notification. It suspends nothing: the third party pays over within thirty days of receiving the seizure.

Common questions

How can they take money without a judge?

A comptable public acts on a title it already holds — an assessment or another enforceable public claim — and the seizure is served directly on the third party. The judicial stage comes afterwards, and only if an opposition is brought and not resolved by the administration.

Does contesting unfreeze the account?

No. The seizure is not suspended by an opposition, and the third party must transfer the funds at the latest within thirty days of receiving it. The two months are about preserving the argument.

I already paid some of it.

Payments already made go to the ground about the amount, which is one of the four article L281 opens. Enclose the proof with the opposition; a request to the service for the composition of the sum is a separate, quicker step.

Which judge hears it if the administration refuses?

That depends on which ground was relied on — form and procedure on one side, the existence or the amount of the debt on the other. It is one of the reasons the opposition has to say which ground it rests on.

Sources

Facts verified against the sources below on 10 September 2026.