India to lead new BRICS working group on International Taxation and Transfer Pricing

At the BRICS Heads of Tax Authorities Meeting in New Delhi on 23 September 2026, two new India-led working groups were formally established, including one covering International Taxation and Transfer Pricing.

The Government describes these as continuing institutional platforms extending beyond an individual BRICS chairship.

The meeting brought together tax administrations from Brazil, China, Egypt, Ethiopia, India, Indonesia, Iran, Russia, South Africa and the UAE.

For businesses, the significance is not an immediate legislative change. The development instead points toward greater institutional cooperation among tax administrations in economies that account for an important part of international investment and trade.

That makes the direction of future work relevant for multinational groups with related-party transactions, cross-border structures or operations spanning BRICS jurisdictions.

Businesses should not change transfer-pricing positions merely because the working group has been created. Existing Indian law and documentation requirements continue to govern Indian transactions.

However, groups operating across multiple BRICS countries may wish to pay particular attention to the consistency of their intercompany agreements, functional analyses, pricing policies and the commercial evidence supporting cross-border arrangements.

The practical question is whether the same transaction tells a consistent story across jurisdictions:

Who performs the functions? Who controls the risks? Where is value created? What do the contractual arrangements say? Does the pricing follow the underlying commercial reality?

International tax cooperation increasingly means that a cross-border transaction cannot be viewed only from the perspective of one jurisdiction.

The stronger approach is to establish the commercial rationale, documentation and pricing architecture when the transaction is designed — not when a tax authority eventually asks questions.