When Transfer Pricing Becomes a Tax on the Global South

Source: The Hindu Business Line | Original Published At: 2026-10-13 09:36:39 UTC

Key Points

• Finance Minister Nirmala Sitharaman called on BRICS tax authorities to jointly address transfer pricing at the BRICS heads of tax authorities meeting.
• Two BRICS working groups are proposed: one on transfer pricing and one on revenue statistics.
• The article says transfer pricing disputes cost developing countries disproportionately, with India accounting for about one-third of global transfer pricing disputes.
• BRICS working groups could pool capacity through shared playbooks, audit standards, and joint positions for advance pricing agreements and mutual agreement procedures.
• The proposed platform would cover treaty interpretation, audits, advance pricing agreements, and mutual agreement procedures.
• The article notes that BRICS+ could serve as a counterweight in global tax rule-making if members adopt a unified negotiating position.
• It says the initiative’s success will depend on delivering concrete outputs such as a shared safe-harbour framework or a common data-sharing protocol.