"Transfer pricing disputes disproportionately burden developing countries." Examine, and discuss how BRICS cooperation can help.

Transfer pricing — the pricing of goods and services exchanged between related entities of a multinational — decides which jurisdiction taxes which slice of profit. Because developing economies are largely source jurisdictions with thin audit capacity, the cost of these disputes falls unevenly on them, a concern the Finance Minister flagged at the BRICS Heads of Tax Authorities Meeting, New Delhi (September 2026) [1][2].

Examining the disproportionate burden

• Slow resolution: transfer pricing cases under the Mutual Agreement Procedure (MAP) took 30.9 months on average to close in 2024, against 24.5 months for other cases, across 141 jurisdictions [3]. The same wait blocks a far larger share of a developing country's revenue.
• Capacity deficit: transfer pricing audits need comparables databases and officers able to defend a position through years of bilateral negotiation — scarce in most source economies.
• Structural asymmetry: profit is typically attributed to residence (headquarters) jurisdictions, while BRICS members sit on the source side [1].
• Weak voice in rule-making: the UN tax convention's terms of reference were adopted 125–9–46; the nine against included the US, UK, Japan and Canada — predominantly headquarters countries [4].

How BRICS cooperation can help

• Institutional permanence: the proposed International Taxation and Transfer Pricing and Revenue Statistics working groups are designed to continue irrespective of the chairship [1].
• Prevention over cure: pooling Advance Pricing Agreement (APA) practice avoids disputes entirely; CBDT signed a record 219 APAs in FY 2025-26, crossing 1,000 cumulatively [5].
• Pair-working: India and Japan were recognised in the OECD's 2024 MAP Awards for cooperation [3] — a model India can seek with each BRICS partner.
• Evidence base: a Revenue Statistics group publishing dispute data annually would substantiate the burden claim itself [1].

Yet APAs and MAPs remain bilateral, so a BRICS position cannot settle any single case. Its real value lies upstream — building audit capacity and a shared negotiating stance in the UN convention talks [4]. Measured over three to four years by whether members' cases close faster than the global average [3], such institutionalised cooperation can convert the Global South's numerical strength into genuine tax certainty.