Practical transfer pricing in the BRICS

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Cookies Settings

Practical transfer pricing in the BRICS

August 31 2012

The BRICS represent five significant transfer pricing jurisdictions for taxpayers. All of them are big investment targets but each of them has a different transfer pricing regime to adhere to. Litigation is on the up in all of them. Sophie Ashley provides an overview of the trends and pitfalls taxpayers are facing in the BRICS and how to get around them.

Unlock this content.

The content you are trying to view is exclusive to our subscribers.

To unlock this content:

Take a Free Trial or Login

Topics

SponsoredCover storyITR MagazineSeptember 2012
more across site & shared bottom lb ros

More from across our site

Transfer Pricing
Australian Company Tax Return concept
IKEA announces intention to dispute A$171m ATO tax claim
The Australian Taxation Office believes the Swedish furniture company has used TP to evade paying tax it owes
Sam Sholli, January 07 2026
Indirect Tax
hmrc large
This month in indirect tax: UK supermarket loses VAT court battle
Supermarket chain Morrisons is facing a £17 million ($23 million) tax bill; in other news, Donald Trump has cut proposed tariffs
Sam Sholli, January 07 2026
Direct Tax
OECD building
Landmark pillar two side-by-side agreement reached
The controversial deal will allow US-parented groups to be carved out from key aspects of pillar two
Tom Baker, January 05 2026
Awards
ITR World Tax 2026 website - 1200x627.png
ITR World Tax 2027 and ITR Tax Awards 2026 opens for submissions
ITR invites tax firms, in-house teams, and tax professionals to make submissions for the 2027 World Tax rankings and the 2026 ITR Tax Awards globally
John Harrison, January 05 2026
Direct Tax
Federico Bertocchi .jpg
EU pillar two directive may violate freedom of establishment: academic
Pillar two was ‘weakened’ when it altered from a multinational convention agreement to simply national domestic law, Federico Bertocchi also argued
Sam Sholli, January 05 2026
Direct Tax
Gold and silver crypto currencies
Brazilian advisers warn of disputes over crypto transaction tax proposals
Imposing the tax on virtual assets is a measure that appears to have no legal, economic or statistical basis, one expert told ITR
Sam Sholli, December 23 2025
Direct Tax
trumpp large
A taxing week: Trump’s pillar two deal won’t save the project
The EU has seemingly capitulated to the US’s ‘side-by-side’ demands. This may be a win for the US, but the uncertainty has only just begun for pillar two
Sam Sholli, December 22 2025
Direct Tax
Business deal mergers and acquisitions
MHA acquires tax and consulting services firm in UAE
The £7.4m buyout marks MHA’s latest acquisition since listing on the London Stock Exchange earlier this year
Sam Sholli, December 22 2025
Direct Tax
2025
Editor’s picks: ITR’s top stories of 2025
ITR’s most prolific stories of the year charted public pillar two spats, the continued fallout from the PwC Australia tax leaks scandal, and a headline tax fraud trial
Tom Baker, December 22 2025
Direct Tax
EU flag large
This week in tax: EU nations drop US pillar two carve-out objections
The climbdowns pave the way for a side-by-side deal to be concluded this week, as per the US Treasury secretary’s expectation; in other news, Taft added a 10-partner tax team
Sam Sholli, December 19 2025
Gift this article