What does a reviewer check before my return is filed?
Not the arithmetic, mainly. The preparer has already done that, and software catches most of what is left. A review of a cross-border filing is looking at what software cannot see: whether the position taken matches the facts the client actually stated, whether the same income is described the same way in both countries' returns, whether every document relied on is in the file rather than remembered from a conversation, and whether something the client mentioned in passing has been left out of the filing altogether. The reviewer is reading for the question an authority would ask.
Why is a reviewer's name and date on my tax advice?
So that the file can answer a question years later about who considered what, and when. Cross-border positions are frequently questioned long after they are taken, by which time the people involved have moved on and the surrounding facts have changed. Advice with a named reviewer and a date attached says that a second person examined the position on a particular day, against the facts and the law as they stood then. Without it, the file holds a conclusion and no record of how it was reached, which is a weak thing to be holding when an authority asks how the position was arrived at.
Is a reviewed return the same as an audited one?
No, and the distinction matters if anyone is relying on it. A review before filing is an internal check, by a second person in the same firm, that the filing says what the facts support and is internally consistent. It is not an audit, it expresses no assurance opinion to a third party, and it does not verify the underlying records the way an audit engagement would. What it produces is a record on the file that the filing was examined by someone other than its preparer before it went out, and of what that person looked at.
Who reviews the return if one person prepared everything?
Someone other than the preparer — that is the whole content of the requirement, and it is why sign-off is recorded by name. The value of a review comes from a second person reading the filing without the preparer's assumptions already in their head, so a preparer checking his own work again produces something else, however careful he is. Where the preparer is the most senior person on that file, the review is done by another reviewer of appropriate standing rather than skipped, and the record shows who it was. A filing that goes out with no separate name against it is a gap, not a formality.
Can a review catch a mistake in the other country's return?
It can, and this is where reviewing a cross-border file differs from reviewing a domestic one. The characteristic error is not a wrong number in one return but two returns that are each defensible on their own and describe the same income differently — a different period, a different characterisation, a conversion done on a different basis. Neither preparer sees it, because each is looking at one return. A review that puts both filings side by side, before either is submitted, is looking for exactly that. Where only one country's return is prepared here, the review checks it against what the other return says.
What happens if the reviewer disagrees with the filing?
The filing waits. In practice disagreement is rarely about the law; it is usually that the reviewer cannot find, in the file, the fact or the document the position depends on. That gets resolved by obtaining it, or by taking a different position, or by filing on the basis available and recording what is missing and why. Any of those can be the right answer. What is not available is filing anyway and settling the question later, because once it is submitted the position is the client's, and knowing what the file could support was the reason for the review.
Is "fund transfer pricing" the same thing as transfer pricing?
No — and if you came here to calculate FTP, this is not it. Fund transfer pricing is a bank's internal allocation of funding costs and benefits between its own business units, a treasury and asset-liability management discipline used to measure branch or product profitability. Tax transfer pricing is about prices between legally separate related parties across borders, and about which country taxes the resulting profit. The words overlap; the fields do not. See our transfer pricing work.
What is cross-border tax?
Cross-border tax is what applies when income, assets or people touch more than one tax system at once — someone living in one country and earning in another, a company selling or hiring abroad, a family holding property in a second country. The work is rarely one country's rules applied harder; it is reconciling two sets of rules and claiming the relief that stops the same income being taxed twice at full rates. See what we do.
