The DGFiP is the administration which, in practice, uncovers tax arrangements: it audits accounts, compares intra-group flows with market conditions, and issues reassessments. The criminal side — the PNF, the CJIP — only comes afterwards, and on the basis of its work.
In the McDonald's case, the two sides are separate and cumulative: €737 million in additional tax and penalties paid to the tax administration, and €508.5 million in public interest fine under the criminal agreement.