Brics to set up working groups on transfer pricing, revenue statistics

Brics countries have agreed to establish two working groups focused on international taxation and transfer pricing, as well as revenue statistics, to enhance cooperation among tax administrations and strengthen their collective voice in global tax negotiations. This announcement was made during a meeting of Brics heads of tax authorities in New Delhi, where Union Finance Minister Nirmala Sitharaman revealed that these groups would serve as an ongoing platform to tackle common challenges, especially for developing-country tax administrations.

Transfer pricing disputes, which involve the pricing of transactions between related companies in different countries, disproportionately impact developing nations, as their tax frameworks may not accurately reflect their fiscal realities, distorting how their tax systems are perceived. The working groups aim to facilitate the exchange of experiences in cross-border taxation and address tax rules that may not adequately address the unique fiscal situations of member countries.

The initiative also seeks to ensure sustained cooperation beyond individual Brics chairships. Brics, a grouping of 11 emerging economies totaling around 40% of global GDP and nearly half of the world's population, includes Brazil, Russia, India, China, South Africa, Egypt, Ethiopia, Iran, the United Arab Emirates, Saudi Arabia, and Indonesia.

The focus on transfer pricing arises from the disproportionate impact these disputes have on developing-country tax administrations, as well as the need for tax frameworks that accurately reflect their fiscal realities. Sitharaman emphasized India's tax administration reforms, which include data-driven and digitally enabled processes, and highlighted the sharing of these practices with Brics partners through the Brics Tax Collaboration Tool.

The International Taxation and Transfer Pricing Working Group will provide a permanent platform for member countries to share their experiences in treaty interpretation, transfer pricing audits, Advance Pricing Agreements (APA), and Mutual Agreement Procedures (MAP), which are mechanisms aimed at providing greater certainty in international taxation and resolving transfer-pricing disputes.