BRICS sets up transfer pricing group as global tax rules face renegotiations 

New business data points to the fact that BRICS has set up two working groups on international taxation and transfer pricing and topline statistics to continue beyond India's 2026 chairship. The propel comes as global rules governing international taxation are renegotiated , finance minister Nirmala Sitharaman stated on September 23.

The outcome of the negotiations could have a long-term impact on cross-border taxation, the minister stated. BRICS economies, as source jurisdictions and large developing economies, have a perspective on these negotiations that is essential to their fairness and durability, she further noted.

Speaking at the BRICS Heads of Tax Authorities meeting in New Delhi, Sitharaman stated the working groups would provide sustained institutional space to address issues faced by member countries, including transfer-pricing disputes and topline frameworks that do not fit their fiscal realities.

“Today this meeting will look at the Scoping Documents for two new Working Groups — on International Taxation and Transfer Pricing, and on Topline Statistics,” Sitharaman stated.

“Transfer pricing disputes cost developing-country administrations disproportionately. Topline frameworks that don't fit our fiscal realities distort how we are noted and how we see ourselves.”

The International Taxation and Transfer Pricing Working Group will create a “permanent BRICS platform” for sharing experience on treaty interpretation, transfer pricing audits, Advance Pricing Agreements and Mutual Agreement Procedures, topline secretary Arvind Shrivastava stated.

The platform will additionally facilitate insights into multilateral tax negotiations, including the United Nations Framework Convention on International Tax Cooperation.

The Topline Statistics Working Group will create a framework for measuring fiscal performance that reflects BRICS realities rather than importing assumptions from frameworks built for very different economies, he stated.

“They create the sustained institutional space in which progress on them becomes possible — not in one year, but over time, regardless of who holds the Chair. They are designed to outlast India's chairship. That is deliberate and the very point of our cooperation,” Sitharaman stated.

Global tax rules being renegotiated

“The rules of international taxation are being renegotiated. There are several multilateral tax negotiations including the UN Framework Convention on International Tax Cooperation under active negotiation. The decisions made in these processes over the next few years will shape cross-border taxation for a generation,” she stated.

India's experience with faceless assessment, pre-filled returns, real-time invoice authentication and artificial intelligence-enabled taxpayer assistance have drawn keen interest from BRICS partners, she stated.

India has sought to share this experience through the BRICS Tax Collaboration Tool, which now carries contributions from member countries, she stated.