1. Failure to comply with the undertakings entered into with a view to obtaining administrative approval or failure to comply with the conditions to which the granting of the latter was subject shall result in the withdrawal of the approval, the forfeiture of the tax benefits attached thereto and the liability for the taxes not paid as a result thereof together with the late payment interest provided for in article 1727, deducted from the date on which these taxes should have been paid.
As an exception to the above provisions, the minister responsible for the budget is authorised to limit the effects of the forfeiture to a fraction of the benefits obtained as a result of the approval.
2. When the beneficiary of tax benefits granted by virtue of an administrative approval or an agreement signed with the State is guilty, subsequent to the date of approval or signature of the agreement, of a tax offence recognised as fraudulent by a judicial decision having the force of res judicata, it shall be deprived of the benefit of the said advantages and the taxes from which it has been exempt since the date of the offence shall become immediately payable, without prejudice to the late payment interest provided for in Article 1727 and deducted from the date on which they should have been paid.