The BRICS have been all the rage from the beginning of the millennium. This book focuses on the shift of power in the global economy from the traditionally dominant nations that comprise the OECD, or, even more narrowly, the G7, to emerging economies, perhaps led by the BRICS. The remodelling of the power structure shaping the global economy and global economic governance more generally is possibly being paralleled by a corresponding reformatting of international taxation. The dominance of the richest countries in the world over the international tax regime that had evolved over the second part of the 20th century is being defied as the 21st century progresses. Emerging economies, within and outside the OECD, assert their newly found power to acquire voice and influence on the international tax agenda. This book is the first to map and analyse the effect of these power shifts on the evolution of the international tax regime in general and on tax treaties that follow the OECD Model in particular. This effect is examined from a wide variety of perspectives and views, considering its substantive tax technical, institutional and political aspects. A leading group of experts contributed to form this new discourse that focuses on, yet is not limited to, the BRICS. They take an independent, scholarly and realistic approach to the various options available to the BRICS and other emerging economies in their quest for a voice in the governance of the international tax regime. The potential for cooperation among the BRICS and similar nations is at the core of the discourse. It is explored in depth on its own and as a primary influence on the emergence of international tax cooperation more generally.