Failure to respond or partial response to the formal notice referred to in III of Article L. 13 AA and in the second paragraph of article L. 13 AB of the Book of Tax Procedures entails the application, for each financial year audited, of a fine that may reach, taking into account the seriousness of the breaches, the higher of the two following amounts:
1° 0.5% of the amount of the transactions concerned by the documents or supplements that have not been made available to the administration after formal notice;
2° 5% of the adjustments to the result based on the article 57 of this code and relating to the transactions mentioned in 1° of this article.
The amount of the fine may not be less than €10,000.