Auditing the taxpayers who account for most of the revenue. Picking the right cases, using indirect methods, and building a file that survives litigation.
A handful of taxpayers account for most of the revenue, and auditing them is a different discipline from volume work. The focus is choosing cases worth the resource, using indirect methods when the records will not give you a straight answer, drawing on exchange-of-information channels, and assembling a file that still stands if the matter is litigated.
Targets audit resources at the highest-risk large taxpayers.
Reconstructs income where records are incomplete or unreliable.
Related-party, financing, and cross-border arrangements.
Uses treaty and exchange channels to obtain foreign information.
Tests intra-group pricing against arm's-length principles.
Documents evidence and reasoning to survive appeal and litigation.
Auditors and case managers in large-taxpayer units and complex audit teams.
Prior tax audit experience is expected. This is advanced work and does not revisit audit fundamentals.
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