Global tax rules being rewritten, BRICS must have greater say: Finance Minister Nirmala Sitharaman

Finance Minister Nirmala Sitharaman on Wednesday said rules governing international taxation are being renegotiated and called for BRICS economies to play a meaningful role in shaping the emerging framework for cross-border taxation.

Addressing the BRICS Tax Head Meeting 2026, Sitharaman said several multilateral tax negotiations, including the UN Framework Convention on International Tax Cooperation, are currently underway. The decisions taken in these processes over the coming years could shape the direction of international taxation for a generation, she said.

“The rules of international taxation are being renegotiated. There are several multilateral tax negotiations including the UN Framework Convention on International Tax Cooperation under active negotiation,” Sitharaman said.

She said the participation of BRICS countries was essential to ensure that the emerging international tax architecture was fair and durable, particularly given their role as source jurisdictions and large developing economies.

“BRICS economies as source jurisdictions, as large developing economies, as countries that have built significant domestic tax capacity from a low base have a perspective on those negotiations that is essential to their fairness and their durability,” she said.

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The comments come amid efforts by developing economies and countries in the Global South to secure a greater role in global tax rule-making, particularly on the taxation of cross-border economic activity and the allocation of taxing rights between source and residence jurisdictions.

India, which held the BRICS summit this year, has proposed two working groups to deepen tax cooperation among member countries. The first will focus on international taxation and transfer pricing, while the second will focus on revenue statistics.

Sitharaman said transfer pricing disputes disproportionately burden developing-country tax administrations, while revenue frameworks that do not reflect their fiscal realities can distort how their economies are assessed.

The International Taxation and Transfer Pricing Working Group will facilitate exchanges on treaty interpretation, transfer pricing audits, advance pricing agreements and mutual agreement procedures, as well as discussions on multilateral tax negotiations.

The Revenue Statistics Working Group will seek to develop a framework for measuring fiscal performance that reflects the economic and fiscal realities of BRICS economies.

Sitharaman said the groups were intended to provide a sustained institutional platform beyond India’s current initiative and ensure continuity as future countries take over the BRICS presidency. China is scheduled to assume the presidency in 2027.

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