Electronic Thesis and Dissertation Repository


Master of Laws




Chios Carmody

2nd Supervisor

Colin Campbell



The rise of the BRICS (Brazil, Russia, India, China and South Africa) as major emerging powers has challenged existing important structures in the global economy. For this reason, there is an expectation that this restructuring may also occur in the international tax regime. In this respect, transfer pricing is one potential area for cooperation between the BRICS, which have faced challenges in applying the existing international standard – the traditional arm’s length approach as established by the OECD – in practice. Therefore, this thesis investigates the differences between the transfer pricing regulations of the BRICS and those of the OECD, examining the potential for cooperation between these countries and their impact on the international tax debate. The author concludes that the substantial differences among the BRICS prevent them from developing a unified and cohesive transfer pricing policy. However, the BRICS have demonstrated an ability to individually influence the international transfer pricing regime.