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Sitharaman Urges BRICS to Unite on Transfer Pricing

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At a BRICS tax meeting in New Delhi, Finance Minister Nirmala Sitharaman said transfer pricing disputes fall hardest on developing nations.

Finance Minister Nirmala Sitharaman on Wednesday called on BRICS nations to pool their experience on treaty interpretation and multilateral tax negotiations, warning that global transfer pricing disputes fall "disproportionately" on developing countries. She was addressing a meeting of BRICS heads of tax authorities in New Delhi.

Sitharaman said India has proposed setting up two new working groups within the bloc: one on International Taxation and Transfer Pricing, and another on Revenue Statistics. The proposals come as the rules governing cross-border taxation are being rewritten.

"The rules of international taxation are being renegotiated," she said. "There are several multilateral tax issues, 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 argued that BRICS members bring a distinct viewpoint to those talks because of their position in the global economy. "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.

Her remarks tied the case for coordination directly to the burden that transfer pricing disputes place on developing economies, which she said carry an outsized share of the cost. By sharing how each country handles treaty interpretation and negotiation, she suggested, the group could strengthen its hand as the international system is reshaped.

The minister framed the current negotiations as a rare window, with outcomes expected to hold for years to come. India's push for the two working groups is aimed at giving BRECS members a more organized platform to compare approaches on taxation and revenue data.

Nirmala Sitharaman, BRICS transfer pricing, international taxation, UN tax convention, developing countries tax, transfer pricing disputes, India tax policy, multilateral tax negotiations

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