Question · Uncertain tax treatments: measure and reassess

Since 20X3 the Belcastor group had measured a transfer pricing uncertainty using the expected value (scattered outcomes). In 20X5, the authority publishes guidance that leaves only two outcomes: full acceptance or full rejection, rejection being the more likely according to its advisers. Write a memo: should the estimate be reassessed, which method should now be used, how should the effect be recognised? Distinguish rule, data and judgement.