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Federico Vincenti and Alessandro Valente of Valente Associati GEB Partners/Crowe Valente review the Italian Supreme Court’s intervention, as companies should anticipate a heavy burden of proof in tax disputes.

Eddie Ahn of DLA Piper Australia outlines the proposed changes to Australia’s thin capitalisation rules, tax deductions for intangibles and tax transparency rules for multinational enterprises.

The clock is ticking on the implementation of the OECD’s pillar two proposals. Phil Myers considers the challenges for companies, the changing role of tax professionals, and how a technology-based solution could help.

Francisca Osório de Castro of Morais Leitão overviews recent case law that could have a significant impact on American nationals’ tax regime in Portugal.

Paul Ashburn and Amit Bhalla of HLB Thailand overview Thailand’s gradual overhaul of its transfer pricing rules, as the concept of secondary adjustments takes shape in the jurisdiction.

Lewis Lu and John Timpany of KPMG China discuss the bright-line test to be introduced for treating certain onshore equity disposal gains as capital in nature and non-taxable.

Raluca Enache, Christiana Loizou and Paulina Laine of KPMG ask whether there is any order in the chaos of the efforts to create a more effective system of withholding tax.

Paolo Ludovici and Andrea Iannaccone of Gatti Pavesi Bianchi Ludovici examine the recent judgment, which declares that even payments between resident entities must be scrutinised.

Nouran Ibrahim of Saleh, Barsoum & Abdel Aziz – Grant Thornton Egypt explains what information local tax teams need to collate for documentation purposes, and how, as audits become more likely and increasingly stringent.