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Maître Reda KOHEN, avocat au Barreau de Paris
Maître Reda KOHEN
Avocat au Barreau de Paris

How to Pay French Corporate Tax from a Foreign Bank Account: SEPA, Tax References and Failed Transfers

For a foreign founder, paying French corporate tax from a bank account outside France is usually possible, but the decisive question is not whether the account has a French IBAN. The account must be usable within the Single Euro Payments Area (SEPA), and the payment must be made through the channel required for the particular tax. For a French subsidiary subject to corporate income tax, known in France as impôt sur les sociétés (IS), the ordinary route is the secure online tax account and télérèglement, meaning an electronic tax payment initiated through the French tax administration. A foreign company without a permanent establishment that has taxable French operations may instead deal with the Service des impôts des entreprises étrangères (SIEE, the foreign-business tax service), but it still has to respect the applicable electronic procedures.

The practical risk appears when a founder sees a “payment accepted” screen while the bank has rejected the SEPA Business-to-Business (B2B) debit, when the tax account contains the wrong bank mandate, or when a normal international transfer is sent without the reference needed for allocation. A rejected debit does not, by itself, extinguish an IS debt or prove that the payment date has been recognised. The company needs a controlled process: identify the tax and deadline, confirm the payment channel, register the foreign account, validate the B2B mandate with the bank, keep the tax reference and obtain evidence of both the order and its settlement. This article explains that process, the response to a failed payment and the legal steps available when the bank or the tax account creates an urgent problem.

For the wider legal choices involved in creating and operating a French company, see the firm’s French company formation support hub for foreign founders. This article addresses payment mechanics and tax recovery. It does not replace an examination of the company’s tax position, treaty status, accounting records or bank contract.

I. How can a foreign-owned French company pay corporate tax from a foreign bank account?

A. Which French taxes and payment channels are covered?

The first distinction is between the place where the bank account is held and the legal entity that owes the tax. A French Société par actions simplifiée (SAS, simplified joint-stock company), Société à responsabilité limitée (SARL, limited-liability company), SASU or EURL normally has its own French tax account and its own tax identity. The shareholder’s foreign account is not automatically the company’s account. A foreign parent may fund the subsidiary, but the payment record must still identify the French taxpayer and the tax period. A branch remains part of the foreign company, so the responsible tax service and the supporting documents may differ from those of a separate French subsidiary.

The official tax administration explains the position for an enterprise established abroad without a permanent establishment in France. Its page on online payment states: “Vous êtes une entreprise étrangère sans établissement stable en France et vous réalisez des opérations taxables en France, vous relevez de la compétence du Service des Impôts des Entreprises Etrangères (SIEE).” It then states: “Vous avez également l’obligation d’effectuer vos paiements en ligne.” The same page explains that electronic payments use the SEPA B2B format. A French company with a French establishment will normally be attached to a different business tax service, but the same electronic-payment discipline remains central for IS and related taxes.

SEPA is a payment area and technical framework, not a promise that every foreign account will accept every French debit. Article 1680 A of the French General Tax Code (Code général des impôts, CGI) says that tax-authority debits are taken from an account held with an authorised institution, including “Un compte de dépôt dans un établissement de crédit établi en France ou dans l’espace unique de paiement en euros”. This is the statutory basis for using an eligible foreign account. A bank account merely described by a fintech as “international” may still fail if the institution or the product cannot receive a French SEPA B2B direct debit in euros.

The tax administration gives the same practical answer in its professional FAQ: “Vous pouvez utiliser une compte bancaire étranger pour adhérer aux procédures en ligne dès lors que ce dernier est bien au format européen SEPA.” The grammar on the administration’s page is imperfect, but the operational point is clear: the account must be in an accepted European SEPA format. The company should ask its bank a precise question: can this legal-entity account receive and honour SEPA B2B direct-debit instructions from the French tax administration, in euros, under the mandate presented in the French professional tax account?

For IS, the relevant payment is generally not an unlabelled payment order typed into the bank’s ordinary international-transfer screen. Article 1681 septies CGI provides, in the version verified for this article, that: “Par dérogation aux dispositions de l’article 1681 quinquies et du 1 de l’article 1681 sexies, l’impôt sur les sociétés ainsi que les impositions recouvrées dans les mêmes conditions, la cotisation foncière des entreprises et ses taxes additionnelles ainsi que la taxe sur les salaires sont acquittés par télérèglement, par les contribuables qui sont définis aux deuxième à dixième alinéas du I de l’article 1649 quater B quater ;” The statutory reference to Article 1681 septies CGI matters because the payment channel is part of compliance, not a cosmetic choice.

The electronic declaration rule points in the same direction. Article 1649 quater B quater CGI states: “I.-Les déclarations d’impôt sur les sociétés et leurs annexes relatives à un exercice sont souscrites par voie électronique.” The full rule is available in Article 1649 quater B quater CGI. The taxpayer normally uses the company’s espace professionnel on impots.gouv.fr, or an EDI channel where an accounting provider transmits data electronically. EDI means échange de données informatisé, or electronic data interchange. EFI means échange de formulaires informatisé, the direct online filing route. Neither acronym changes the identity of the debtor or the need to reconcile the payment in the tax account.

The amount of tax must also be distinguished from the payment method. Article 219 CGI currently states: “Le taux normal de l’impôt est fixé à 25 %.” That rate is not a personal calculation for every foreign-owned company. Special rates, reduced-rate conditions, tax credits, group taxation, permanent-establishment issues and treaty rules can affect the final liability. The article is useful here only to show that the amount displayed in the tax account should be tested against the company’s tax computation; the bank should not be asked to decide whether the assessment is correct.

The main payments that a foreign founder may encounter include:

  • IS instalments and the final balance;
  • value added tax (VAT), called taxe sur la valeur ajoutée or TVA in France;
  • the cotisation foncière des entreprises (CFE), the local business-property contribution;
  • payroll-related taxes, including the taxe sur les salaires where applicable; and
  • other taxes shown in the company’s professional tax account.

The account and mandate may cover more than one tax, but each payment must still be matched to the correct form, period and reference. The official tax administration’s international-professional page lists online payment for the principal taxes and explains the distinction between direct EFI use and an EDI provider. A foreign founder who has delegated filing to an accountant should obtain a written division of responsibility: who submits the return, who initiates the payment, who monitors the bank rejection messages, and who confirms that the debit has settled in the tax ledger.

The choice between a SEPA debit and a transfer is not always free. Article 1681 sexies CGI provides that, subject to its listed exceptions, when the amount exceeds €50,000, taxes payable under Article 1663 are paid, at the taxpayer’s choice, by a transfer to the Treasury account at the Banque de France or by a tax-authority debit from an account covered by Article 1680 A. The current text is linked here as Article 1681 sexies CGI. That provision should not be read as permission to replace a mandatory online IS payment with an ordinary bank transfer whenever a debit fails. The tax service may need to give precise instructions for an exceptional transfer, including the beneficiary account and allocation reference.

The official online-payment page also says that a foreign enterprise subject to French tax must use an account held with an institution reachable for SEPA B2B debit. The page is old in presentation, so a company should verify the current screen and bank instructions in its professional account immediately before payment. The legal basis and the operational interface must be read together: one establishes eligibility, the other determines whether the payment can actually be initiated.

B. What must a company prepare before its first SEPA payment?

A foreign founder should treat the first payment as a project with a file, not as a last-minute bank instruction. The company’s registration details must be consistent across the tax account, bank account and accounting system. The Kbis is the official extract for a company registered in the French Registre du commerce et des sociétés (RCS, the commercial and companies register). The greffe is the court registry that processes the relevant commercial registration. The SIREN is the nine-digit national business identifier; a SIRET adds a five-digit establishment identifier. The French national business register is the Registre national des entreprises (RNE), operated through the Institut national de la propriété industrielle (INPI, the French National Institute of Industrial Property).

The INPI explanation of documents proving a company’s existence distinguishes the RNE registration certificate from the Kbis and explains that the Kbis is delivered by the competent greffe. In the live link, remove the space after “demarches/” if a browser has inserted it; the stable INPI page is also available at Documents justifying the existence of a company. A foreign parent’s incorporation certificate or home-country register extract may be needed in addition to the French company’s Kbis. The bank and the tax administration are asking different questions, so one document should not be assumed to satisfy both.

Before the first payment, assemble the following information in a controlled folder:

  1. The exact legal name of the taxpayer, its SIREN and, where relevant, its SIRET.
  2. The tax service shown in the company’s espace professionnel: SIE for a French business service or SIEE for a foreign enterprise without a permanent establishment.
  3. The tax type, tax period, declaration number, amount and payment deadline.
  4. The company bank account’s IBAN, meaning International Bank Account Number, and BIC, meaning Bank Identifier Code.
  5. Confirmation that the bank accepts SEPA B2B direct debits for that account and currency.
  6. The signed SEPA B2B mandate and its RUM, the Référence Unique de Mandat or unique mandate reference.
  7. The name and authority of the person allowed to administer the professional tax account.
  8. A route to obtain same-day proof from both the bank and the tax account after the debit is presented.

The tax administration’s official page on the B2B mandate is unusually direct. It states: “Pour tout nouveau compte déclaré dans l’espace professionnel, pour payer des impôts et taxes auto-liquidés (TVA, Impôt sur les Sociétés, Taxe sur les Salaires, CVAE, TCA, TVS), il est indispensable de faire parvenir à votre établissement bancaire, préalablement à votre premier paiement à l’aide de ce compte, votre mandat SEPA de prélèvement interentreprises (ou mandat B2B) signé.” The page explains that the pre-filled mandate is found through “Gérer mes comptes bancaires” and “Editer le mandat”. It also says the RUM must be communicated to the bank. The source is the official SEPA B2B mandate page.

This step is often missed by founders who have a perfectly valid European IBAN. The tax account may show the bank account as added, but the bank’s internal mandate file may not yet authorise the creditor’s B2B collection. Ask the bank for confirmation that the mandate has been accepted at account level. Keep the confirmation, the mandate, the RUM and the bank’s name exactly as recorded. If a treasury department or parent company controls the account, make sure its internal approval process does not expire before the debit date.

The calendar must be built from the company’s accounting year-end. Article 1668 CGI states: “Les paiements doivent être effectués au plus tard les 15 mars, 15 juin, 15 septembre et 15 décembre de chaque année.” Those dates concern the normal quarterly IS instalment pattern; the exact instalment depends on the company’s closing date and prior taxable result. The same article states that newly created companies or companies newly subject to IS are exempt from instalments during the first financial year or first tax period in the circumstances covered by the text. It also provides that the final balance is paid with the relevé de solde, meaning the balance statement, no later than the 15th day of the fourth month following the end of the financial year; for a 31 December year-end, the provision sets a 15 May deadline.

Article 1668 also says: “S’il résulte de cette liquidation un complément d’impôt, il est acquitté lors du dépôt du relevé de solde au plus tard le 15 du quatrième mois qui suit la clôture de l’exercice.” The wording should be read with the tax return and current filing instructions. A foreign founder should not rely on a group reporting calendar prepared in another country. Put the French deadline, the Paris time zone where relevant, the bank cut-off and the accountant’s submission date in one calendar. A payment order started on the deadline may be too late if the account is not funded or the mandate is rejected.

For ordinary direct-tax collection, Article 1663 CGI provides: “Les impôts directs, produits et taxes assimilés, visés par le présent code, sont exigibles trente jours après la date de la mise en recouvrement du rôle.” This rule concerns taxes collected by role and does not replace the special IS calendar. It illustrates why the document displayed in the tax account must be identified correctly. A role, a tax return and a tax notice are not interchangeable documents.

The company should run a dry check before the first real debit. The administrator can enter the foreign account in the professional tax account, download the mandate, send it to the bank, obtain acceptance, and confirm that the account name and SIREN are consistent. The accounting team can then record the expected tax amount and keep the payment reference. The founder should ask for a screenshot or PDF of the tax account before payment and another after settlement. A bank statement showing money leaving the account is helpful, but the tax account’s allocation is the evidence that the French debt has been matched.

If the bank refuses the account or will not support the needed service, the company can examine the French right-to-account procedure, while remembering that a designated bank’s basic services do not automatically solve every cross-border treasury requirement. Service Public Entreprendre explains the professional right to an account, including the bank’s 15-day period to issue a refusal certificate and the possibility of asking the Banque de France to designate an institution. The company should preserve the refusal, its Kbis, authority documents and proof of the request. A foreign SEPA account that already satisfies Article 1680 A may still be a faster solution than waiting for a new French account, provided the tax administration and bank confirm that the exact B2B mandate works.

II. What should a foreign founder do when a payment fails or the deadline is near?

A. How should the company diagnose a rejected debit, transfer or tax-account mismatch?

Start by classifying the event. There are at least four different failures: the tax account refused to initiate the payment; the bank rejected the direct debit; the money left the account but the tax ledger did not allocate it; or an ordinary transfer was sent without a valid instruction or reference. Each event requires a different response. Calling the bank and asking whether “the French tax payment worked” is not enough. Ask for the SEPA transaction status, the rejection code, the date and time of presentation, the creditor identifier if available, the mandate reference, the reason for refusal and whether the bank can re-present the debit.

At the same time, open the company’s professional tax account and record the exact status. Look for a pending order, a rejected order, an unpaid balance, a duplicate payment, a credit awaiting allocation or a message from the responsible tax service. Save the page as a PDF or screenshot, including the date and the taxpayer identity. If an accountant initiated the payment through EDI, request the transmission report and the acknowledgement of receipt. An EDI acceptance can show that a file was received; it does not necessarily prove that the bank debit settled or that the tax account was credited.

The usual technical causes are predictable:

  • the foreign bank is in SEPA but the particular account does not accept B2B direct debits;
  • the mandate was signed but was not lodged with the bank before the first collection;
  • the RUM or account details do not match the tax account;
  • the company changed banks without updating the professional tax account;
  • the account had insufficient cleared funds or a treasury approval limit;
  • the debit was presented after a bank cut-off or on a non-processing day;
  • the bank’s compliance team blocked a new cross-border debit; or
  • the payment was made against the wrong company, period or tax type.

Do not send a second payment blindly. A duplicate can create an unexplained credit while the original debt remains marked unpaid, particularly where a transfer lacks the correct taxpayer reference. First ask the SIE or SIEE how it wants a replacement payment made. If the tax office provides a written transfer instruction, use the exact beneficiary details and reference. Keep evidence that the instruction came from the responsible service and do not substitute a parent’s personal account for the company without documenting the legal and accounting basis.

If the payment was a SEPA direct debit and the bank says the mandate was invalid, compare the signed document with the mandate registered in the tax account. The bank may have rejected an account-level rule, a creditor-category restriction or a compliance review rather than the company’s tax liability. The Cour de cassation, Commercial Chamber, 24 May 2018, no. 17-11.710, held in a banking dispute that, “sauf anomalie apparente, non alléguée en l’espèce, le prestataire de services de paiement n’est pas tenu de s’assurer de l’existence du mandat de prélèvement donné par le payeur au bénéficiaire, préalablement à l’exécution de l’ordre de prélèvement donné par celui-ci”. The decision is not a ruling on French corporate tax. It is a warning about evidence: the bank, the creditor and the account holder may each hold a different part of the mandate record, and the company must identify which part failed.

The company should also distinguish an unauthorised debit from a rejected authorised debit. For an unauthorised payment, the protections in the Monetary and Financial Code may apply. Article L. 133-18 provides for repayment of an unauthorised operation after the payment service provider is informed, subject to the statutory conditions and fraud exception; the text is available at Article L. 133-18 of the Monetary and Financial Code. That is different from a correctly authorised tax debit that was rejected for lack of funds, an inactive mandate or a bank control. A request for repayment or a bank complaint does not automatically settle the company’s tax debt.

The same separation appears in Cour de cassation, Commercial Chamber, 2 July 2025, no. 24-11.680. In a case involving SEPA collections and the liquidation of the beneficiary, the Court stated: “lors d’un prélèvement SEPA le payeur jouit d’un droit au remboursement par son prestataire de services de paiement d’une opération de paiement ordonnée par son bénéficiaire à la condition de présenter sa demande de remboursement avant l’expiration d’une période de huit semaines à compter de la date à laquelle les fonds ont été débités.” The case concerned the relationship between payment-service rules and insolvency, not an IS debt. Its practical lesson is still important: a bank return or refund is a payment-system event; it does not by itself determine whether the underlying tax claim has been paid, disputed or remains due.

Next, quantify the legal exposure. Article 1727 CGI states: “Toute créance de nature fiscale, dont l’établissement ou le recouvrement incombe aux administrations fiscales, qui n’a pas été acquittée dans le délai légal donne lieu au versement d’un intérêt de retard.” The current Article 1727 CGI sets the interest rate at 0.20% per month and explains the calculation period. Article 1731 CGI separately states: “Donne lieu à l’application d’une majoration de 5 % tout retard dans le paiement des sommes qui doivent être versées aux comptables de l’administration fiscale au titre des impositions autres que celles mentionnées à l’article 1730.” The Article 1731 CGI text should be read with the tax concerned; the 5% rule is not a universal label for every late IS event.

The payment date can matter. In Conseil d’État, 14 April 2023, no. 467622, a VAT dispute, the Court interpreted Article 1727 and held that the rules “n’ont pas pour objet et ne sauraient avoir pour effet de faire obstacle à ce que ce décompte soit arrêté au dernier jour du mois du paiement, conformément au 1 du IV de ce même article, lorsque le contribuable a procédé à ce paiement avant la notification de cette proposition.” This is not a blanket rule that a failed bank order counts as payment. It shows why the company should establish what actually happened: when the payment was ordered, when funds were debited, when the Treasury received them, and when the tax service allocated them.

B. How can the company regularise, preserve proof and use the right remedy?

When the deadline is close, use a written escalation sequence. First, contact the bank’s payments or SEPA team, not only the relationship manager, and ask whether the mandate is active for B2B collections from the French tax administration. Second, contact the SIE or SIEE through the channel shown in the professional tax account and give the SIREN, tax type, period, amount, deadline, payment attempt date, mandate reference and bank rejection code. Third, ask whether the original order can be re-presented or whether the service authorises a transfer. Fourth, if the debt is undisputed, pay the principal through the channel confirmed by the tax service and ask for written allocation. Fifth, send a short follow-up with the bank receipt and tax-account evidence so the file has a single chronology.

The chronology should use exact dates and amounts. A useful evidence table records: the return submitted; the relevant tax reference; the amount shown; the order timestamp; the bank’s presentation date; the rejection or settlement code; the date funds left the account; the tax-account status; every call or message to the bank; every message to the SIE/SIEE; and the final allocation. Add the Kbis or RNE certificate, the company’s authority documents, the signed B2B mandate, the RUM, the bank confirmation and the accounting entry. Keep the original files in UTF-8 and preserve the bank’s wording without rewriting a rejection code into an informal summary.

If the company accepts the tax amount but disputes a penalty or asks the administration to recognise a payment made before the deadline, make that request separately from the banking complaint. Explain the payment path and attach the evidence. Do not state that a tax debt disappeared merely because the bank refunded a debit. Ask for an updated account statement showing whether the principal, interest and any majoration remain outstanding.

If the company disputes the basis or amount of the tax itself, the relevant route is a tax claim, not simply a request to the bank. Article L. 277 of the Book of Tax Procedures provides: “Le contribuable qui conteste le bien-fondé ou le montant des impositions mises à sa charge est autorisé, s’il en a expressément formulé la demande dans sa réclamation et précisé le montant ou les bases du dégrèvement auquel il estime avoir droit, à différer le paiement de la partie contestée de ces impositions et des pénalités y afférentes.” The same article says that the tax debt’s enforceability and the limitation period for recovery are suspended until a final decision on the claim, and it can require guarantees above the prescribed threshold. A sursis de paiement, or payment deferral during a tax dispute, must therefore be requested expressly and handled with the guarantees and procedural requirements that apply.

If the tax office has begun recovery, the company must identify the act received. Article L. 257-0 A of the Book of Tax Procedures states: “A défaut de paiement de l’acompte mentionné à l’article 1663 C du code général des impôts ou des sommes mentionnées sur l’avis d’imposition à la date limite de paiement ou de celles mentionnées sur l’avis de mise en recouvrement, le comptable public adresse au redevable la mise en demeure de payer prévue à l’article L. 257 du présent livre avant la notification du premier acte de poursuite devant donner lieu à des frais”. The official text is linked as Article L. 257-0 A. The wording “mise en demeure de payer” means a formal demand to pay; it is not the same as a bank notification that a debit was rejected.

Article L. 257 adds: “Les comptables publics peuvent notifier au redevable une mise en demeure de payer pour le recouvrement des créances dont ils ont la charge.” It also says that the notification interrupts the limitation period for recovery and can be contested under Article L. 281. See Article L. 257. If the company receives a formal demand, it should not answer only through the bank. It should verify the debt ledger, pay any undisputed sum if appropriate, and obtain legal advice on the correct tax claim or recovery challenge.

For a dispute about the recovery act itself, Article L. 281 of the Book of Tax Procedures states: “Les contestations relatives au recouvrement des impôts, taxes, redevances, amendes, condamnations pécuniaires et sommes quelconques dont la perception incombe aux comptables publics doivent être adressées à l’administration dont dépend le comptable qui exerce les poursuites.” This route concerns collection, such as whether a payment was credited, whether the amount remains due or whether the act is regular. It is distinct from challenging the taxable base or rate.

The founder should also avoid a common cross-border mistake: using a shareholder’s personal account to make a company payment without a traceable authorisation. The payment may be economically funded by the parent or founder, but the French company remains the tax debtor in its own records. A 50% shareholder’s control of a foreign company account was examined by the Conseil d’État in Conseil d’État, 8 March 2023, no. 463267, which held, in its own tax context, that the relevant account had been “utilisé” by the individual and had to be declared under the applicable rules. That decision does not decide how a French company should pay IS. It illustrates why personal tax reporting, company tax payment and the ownership of the bank account must be analysed separately.

If the problem is a blocked bank account rather than a disputed tax, ask for a temporary payment solution in writing. A new French account may be useful, but opening it can require a current Kbis, beneficial-owner evidence, the foreign parent’s register documents, an ownership chart and proof of the representative’s authority. The French right-to-account procedure can protect continuity of essential banking services, including payments by direct debit or transfer as described by Service Public, but it does not guarantee that the first bank chosen will accept the company’s full international treasury model. A compliant SEPA account already held abroad may be simpler if its B2B capability is confirmed.

Finally, make the control permanent. Put every French tax deadline in a shared calendar; set an internal payment date several business days before the legal date; keep the bank mandate and RUM in the treasury file; test the professional tax account after each bank change; give the accountant and the foreign parent a single responsibility matrix; and reconcile the tax ledger after every payment. The objective is not merely to prove that someone clicked “pay”. It is to prove that the right company, the right tax, the right period and the right amount were connected to a valid payment that the French administration recognised.

Conclusion

A foreign bank account can be used to pay French corporate tax when it is eligible under the SEPA framework and supports the payment mechanism required by the tax administration. For IS, the normal route is online télérèglement through the company’s professional tax account, with the foreign account registered and the signed SEPA B2B mandate delivered to the bank before the first payment. The company must then preserve the tax reference, the RUM, the bank’s presentation and settlement evidence, and the tax account’s final allocation.

When a payment fails, classify the failure before sending another amount. Check the mandate, bank capability, account status, tax reference and tax ledger; obtain the rejection code; notify the correct SIE or SIEE; and request written instructions for any replacement transfer. Interest, a 5% majoration, a mise en demeure or recovery action may follow a missed deadline, while a genuine dispute about the tax amount may justify an expressly requested sursis de paiement under the Book of Tax Procedures. The strongest file is chronological, entity-specific and supported by official records from the bank and the French tax account.

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Source : Cour de cassation – Base Open Data « Judilibre » & « Légifrance ».

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chaymaa aouadi
5 months ago

I called upon Maître Reda Kohen, a real estate lawyer in Paris, and I am fully satisfied with his support. Very professional, responsive and attentive. He quickly analyzed my case, clearly explained the legal strategy and effectively defended my interests. Thanks to his expertise and determination, we obtained a very favorable outcome. I highly recommend Maître Kohen to anyone looking for a real estate lawyer in Paris.

Translated from French

Reply from the firm

A big thank you for this feedback. It is exactly this kind of return that gives full meaning to our commitment to real estate law in Paris. Your satisfaction is our best recommendation.