Evaluate the role of BRICS in international tax cooperation.

The BRICS Heads of Tax Authorities (HoTA) forum, supported by a tax-experts track and a Young Tax Professionals (YTP) working group, is the grouping's platform for tax-administration cooperation, now running under India's fourth BRICS Chairship (from January 2026). Its worth lies less in making rules than in building bargaining power inside global tax forums.

Contributions

• Administrative cooperation below the political level: the 2021 HoTA meeting under India's chairship addressed digitalisation of tax administration, use of technology against evasion, and the shift from enforcement to taxpayer service [1] — cooperation needing no treaty.
• Capacity building where the real gap lies: the YTP workshop at NADT, Nagpur (April 2026) trained officers from BRICS and partner states in BEPS, Pillar One/Two and transfer pricing [2]. This matters because developing countries received data on about 40 million financial accounts worth EUR 2.7 trillion under automatic exchange, yet 43 have not fixed a date for their first exchange [3].
• Collective bargaining: with the UN Framework Convention on International Tax Cooperation (terms of reference adopted August 2024) giving every state an equal vote [4], a common BRICS line carries real weight.
• Defending source-country rights: joint adoption of the Subject to Tax Rule, which lets developing countries tax intra-group payments taxed abroad below a 9% nominal rate [5].

Limitations

• BRICS has no treaty, secretariat or dispute mechanism — HoTA ends in a communiqué, not an enforceable rule.
• The binding rules are written elsewhere: the 15% GloBE minimum effective rate emerged from the OECD/G20 process [6].
• Divergent interests — capital-exporting China versus source economies like India and South Africa — and enlargement make consensus harder.
• Domestically, Indian incentives pushing effective rates below 15% merely surrender revenue as top-up tax abroad [6].

BRICS is therefore a coordination forum, not a law-making one — judged rightly by whether members vote together, not by declarations issued. India's chairship should convert it into a joint STTR push, open NADT training to African and South Asian officers, and carry an agreed BRICS position into the UN talks before the text closes — advancing the equitable global governance that SDG-17 envisages.