BRICS should work together on transfer pricing as disputes burden developing nations: FM

Finance Minister Nirmala Sitharaman has urged BRICS nations to collaborate on international taxation, particularly in transfer pricing disputes that disproportionately affect developing countries, at a meeting in New Delhi. India has proposed establishing two new working groups focused on International Taxation and Transfer Pricing, as well as Revenue Statistics, during the renegotiation of global tax rules.

These rules are being actively discussed in various multilateral agreements, including the United Nations Framework Convention on International Tax Cooperation. The decisions made in these negotiations will significantly impact cross-border taxation for years to come.

Sitharaman emphasized that BRICS nations, as large developing economies and source jurisdictions, possess valuable insights into these negotiations, which are essential for their fairness and longevity. Transfer pricing, the pricing of goods and services exchanged between related companies, often leads to international transfer pricing disputes.

These disputes stem from differing interpretations of which profits should be subject to tax in each jurisdiction, causing conflicts between taxpayers, tax authorities, and even tax authorities across different countries. Developing countries, in particular, bear a disproportionate burden due to revenue frameworks that do not align with their fiscal realities.