What changed.
Why it matters.
What businesses should consider.

What changed

BRICS tax authorities have formally established a new working group on International Taxation and Transfer Pricing, to be led by India. The initiative creates an ongoing institutional platform for cooperation among BRICS tax administrations.

Impact

There is no immediate change to Indian transfer-pricing law or compliance obligations. However, multinational groups operating across BRICS jurisdictions should watch the initiative as tax administrations deepen cooperation on international-tax and transfer-pricing matters.

What changed

The OECD/G20 Inclusive Framework released a package covering the full legislative-review process, an updated GloBE Information Return and further Administrative Guidance for the Global Minimum Tax.

Impact

In-scope multinational groups should consider whether their GloBE data, reporting systems and compliance processes reflect the updated GIR and September guidance, particularly as jurisdictions move from implementation toward review and coordinated administration.

What changed

The OECD published stakeholder comments on proposed revisions to Chapter VII of the Transfer Pricing Guidelines concerning intra-group services. The proposals seek to modernise and clarify the guidance and add practical examples. They are NOT final rules.

Impact

Multinational groups charging management, administrative, technical or other intra-group service fees should follow the process closely. The direction of the work reinforces the importance of establishing the actual service, benefit, allocation methodology and arm's-length pricing.