Cal. Rev. & Tax. Code § 41133.4

Upon completion of the managed audit and verification by the department, interest on any unpaid liability shall be computed at one-half the rate that would otherwise be imposed for liabilities covered by the audit period. Payment of the liabilities and interest shall be made within the time period specified by the department. If the requirements for the managed audit are not satisfied, the department may proceed to examine the records of the service supplier or seller in a manner to be determined by the department under law.