Outside expertise will allow the UK tax authorities to attack transactions they view as risky with a whole new level of sophistication, says Ted Keen of the Ballentine Barbera Group, a CRA International company. UK taxpayers who have not yet done so should revisit their transfer pricing documentation, particularly where transfers of valuable intangible property are concerned
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Effective audit management requires more than documentation; it’s the way taxpayers engage that can shape audit direction, manage procedural ambiguity, and preserve options for appeal or litigation
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