— The concept of UHF RFID passive tag-totag communication has been introduced and opens new promising perspectives in the field of Internet-of-Things. This concept enables two powerless tags to exchange information using an external source. Moreover, a simulation framework has been proposed as a tool allowing the performance evaluation of tag-to-tag radio links in terms of Bit Error Rate (BER). The aim of this paper is to provide a theoretical framework for BER estimation. The theoretical framework takes into account various parameters such as modulation rate, receivers topology and the electromagnetic coupling of the tags. Furthermore, in order to validate the obtained results, they are compared with the ones obtained by realistic simulations.