New Delhi, Sep 23: Finance Minister Nirmala Sitharaman on Wednesday said transfer pricing disputes “disproportionately” burden developing countries, as India advocated for setting up two new BRICS working groups dedicated to taxation.
Addressing a meeting of the BRICS heads of Tax authorities, Sitharaman said the meeting will look at the Scoping Documents for two new Working Groups — on International Taxation and Transfer Pricing, and on Revenue Statistics.
“Transfer pricing disputes cost developing-country administrations disproportionately. Revenue frameworks that don’t fit our fiscal realities distort how we are seen and how we see ourselves. These Working Groups exist because every country in this room has experienced these problems,” Sitharaman said.
The Minister added that the working groups would create sustained institutional space for progress over time, regardless of who holds the Chair.
“They are designed to outlast India’s Chairship,” Sitharaman said.
China will take over the rotating BRICS Presidency in 2027.
The Minister further said that the rules of international taxation are being renegotiated through 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. BRICS economies — as source jurisdictions, as large developing economies, as countries that have built significant domestic tax capacity from a low base — have a perspective on those negotiations that is essential to their fairness and their durability,” Sitharaman said.
India’s Chairship is not defined merely by today’s decisions, It is meant to build on past achievements to establish a strong foundation for future leadership.
Sitharaman outlined the main outcomes of this year’s BRICS tax track: using technology to make tax administration more precise and reduce individual discretion, while prioritising shared governance standards and investment in people, especially youth.
Revenue Secretary Arvind Shrivastava said BRICS tax experts have spent two days reviewing the scope of work of the working group.
The International Taxation and Transfer Pricing Working Group creates a permanent BRICS platform for sharing experience on treaty interpretation, transfer pricing audit, APA (advance pricing agreement) and MAP (Mutual Agreement Procedure) mechanisms, and the multilateral negotiations including the UNFCITC (United Nations Framework Convention on International Tax Cooperation) — where our collective voice is needed and currently insufficient.
The Revenue Statistics Working Group creates a framework for measuring fiscal performance that reflects BRICS realities rather than importing assumptions from frameworks built for very different economies, Shrivastava said.
