How can India's BRICS chairship institutionalise Global South cooperation on taxation?

Transfer pricing — the pricing of goods and services between related firms — decides where multinational profits are taxed. With global tax rules being renegotiated at the UN, India's 2026 BRICS chairship is an opportunity to convert Global South solidarity into permanent machinery rather than summit language.

The gap that institutions must fill

• Capacity, not intent, is the bottleneck: transfer pricing cases under the Mutual Agreement Procedure (MAP) took 30.9 months on average to close in 2024 across 141 jurisdictions [2]. Developing administrations, with thinner specialist cadres, absorb such delays worst.
• Numbers without leverage: the terms of reference for the UN Framework Convention on International Tax Cooperation were adopted 125–9–46, yet the nine opposing states included headquarters economies like the US, UK, Japan and Canada [3]. A majority can write rules; it cannot alone deliver revenue.

How the chairship can institutionalise cooperation

• Permanent platforms: the BRICS Heads of Tax Authorities Meeting in New Delhi established India-led working groups on International Taxation and Transfer Pricing and on Revenue Statistics, designed to function independent of annual chairships [1].
• Skilling the administrations: the Young Tax Professionals Capacity Building Programme (first in-person edition at Nagpur) was made an annual fixture, and a Tax Cross-Learning Lab launched for structured peer learning [1].
• Prevention over litigation: scale bilateral Advance Pricing Agreements, and replicate the India–Japan pairing recognised in the OECD's 2024 MAP Awards for resolving the most transfer pricing cases [2].
• Comparable data as evidence: the Revenue Statistics group should publish BRICS dispute and revenue figures annually, as the OECD does [2], substantiating the developing-country burden in negotiations [3].
• Handover discipline: the signed BRICS Tax Progress Report 2026 and China's incoming 2027 chairship of the tax track institutionalise continuity [1].

Institutionalisation, therefore, lies less in declarations than in standing groups, trained officers and published data. If India anchors these, its chairship will leave behind durable fiscal capacity — strengthening the Global South's voice in a fairer, more inclusive international tax order and advancing SDG 17.1 on domestic resource mobilisation.