The Kervadin group deducted in 20X5 head-office costs recharged to three subsidiaries in the same country, using an allocation key that the authority challenged during an audit of another company in the sector. Its advisers consider rejection more likely than acceptance; Kervadin argues that it has not been audited for eight years. Write an analysis memo (unit of account, examination assumption, probability of acceptance, consequence), distinguishing rule, case data and judgement.
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