What the correspondence representative actually is
The correspondence representative sits in a much quieter corner of French tax procedure than the accredited fiscal representative, and the two are routinely confused. In legal terms the role is a postal and procedural relay: a French-resident person or firm who agrees to receive any notice that the tax administration sends to a non-resident, to answer formal queries within the legal deadlines, and to forward information to the taxpayer abroad. The role does not carry the Article 244 bis A guarantee, it does not cover the capital gains tax on a sale, and it does not satisfy the accreditation test. Its purpose is continuity. A non-resident who owns a French flat rented out to tenants, who receives rental income, who pays the wealth tax on French real estate, who might one day face an IFI adjustment, simply needs a reliable counterparty at a French address so that nothing important is lost in international mail.
The 90-day window, decoded
The 90-day figure is administrative shorthand, not a single line in the tax code. It captures the window within which the correspondence representative is expected to have received, acknowledged and answered a formal administrative notice. In practice the clock is shorter for some procedures: a mise en demeure (formal notice) usually allows 30 days, a demande d informations sometimes 60. Taken together, 90 days is the outer bound that firms use when they scope the correspondence mandate, because the real bottleneck is not the mail, it is the delay between the French office sending a letter and the non-resident abroad actually responding with the right documents. If your representative is halfway across the world and has to dig out an old notarial act, 90 days is about right. If a letter is ignored, the administration can proceed to taxation d office with penalties that are painful and surprisingly difficult to unwind afterwards. Missing the window is therefore expensive even when the underlying tax question was neutral.
Which role fits your situation
The rough rule of thumb is to match the role to the event, not to your status. If you are selling a French property and the sale triggers Article 244 bis A, you need an accredited fiscal representative for that transaction, full stop. If on top of that you own another French property that you rent out, or if you keep the French apartment after the sale for a sibling, you may also want a correspondence representative for the ongoing flow of letters. If you are neither selling nor earning French income but you hold a French asset that appears on the IFI radar, the correspondence role is the lightweight option and the accredited one is overkill. Many firms offer both mandates and will bundle them at a noticeably lower combined fee; watch out for firms that try to push the full accredited mandate when the postal relay is all you need.
Worked example
Marc, a Canadian resident, inherited a small Nice studio from his mother in 2014 and has been renting it out ever since. He does not intend to sell. His situation calls for two things, and only two: a French tax number kept alive, which he already has, and a correspondence representative, because once a year the Nice tax office sends him a letter that needs answering inside 60 days. He signs a mandate with a Marseille firm for €220 a year, the firm receives the letter, emails him a scan within 24 hours, and returns the signed response on his behalf using a pre-agreed power of attorney. No accredited mandate is needed because there is no sale; the fiscal representative question only arises the day Marc decides to sell the studio.
Pitfall to avoid
The trap is thinking that an accredited fiscal representative appointed for a single sale will keep handling your mail afterwards. Their mandate closes with the tax clearance on the sale, and any letter that arrives a year later falls through the cracks. We have seen non-residents discover, fifteen months after selling, that the administration raised a small adjustment and sent three letters to the French address of the now-discharged representative. The fourth letter was a taxation d office with penalties. If you keep any French footprint after a sale, even a tiny one, arrange a correspondence mandate the same day the sale closes, not later.
Pro tip
Ask your candidate firm to include an automatic acknowledgement clause in the correspondence mandate. The clause commits them to confirming receipt of any French tax letter within 48 hours by email, scanned, with a flag on the stated deadline. It costs nothing extra because a serious firm does it already, and it protects you if the firm later argues that a missed deadline was not their fault. A written clause is the difference between a weak commercial promise and an enforceable professional obligation.
Key takeaways
- The correspondence representative is a postal and procedural relay, not a tax guarantor.
- The 90-day figure is administrative shorthand; the binding deadlines are 30 or 60 days depending on the procedure.
- A sale above €150,000 from outside the EU/EEA still needs an accredited representative, not just a correspondence one.
- The two mandates can be held by the same firm but cover different risks and fees.
- If you keep any French footprint after selling, open a correspondence mandate the day the sale closes.
- Insist on a 48-hour acknowledgement clause in writing; it converts a promise into an obligation.
Frequently asked questions
Is the correspondence representative the same thing as a fiscal representative?
No. The accredited fiscal representative guarantees the tax owed on a real-estate sale under Article 244 bis A. The correspondence representative is a French address for routine tax correspondence, typically linked to rental income or wealth tax. Different legal status, different liability, different fee level.
Do I still need an accredited representative if I have a correspondence representative?
Almost always yes for a sale above €150,000 from outside the EU/EEA. The correspondence role does not cover Article 244 bis A. The two roles can be held by the same firm, but the mandates are distinct and the paperwork is separate.
Where does the 90-day number actually come from?
From the administrative practice of the tax office, not from a single decree. The authority expects a response to any formal notice within 30 or 60 days depending on the procedure; the 90-day figure covers the outer bound used by the correspondence representative mandate and by most firms when they quote a response window.
Can I simply ask my notaire to forward my mail?
That is not the same service. A notaire handles deed-related correspondence, not the French tax administration. If you want tax letters to land somewhere reliable and be answered, you need a professional mandate, usually a correspondence representative or your accredited firm keeping the relationship open post-sale.