Nepal is in DTAA agreement with 11 different countries. A short comparative study of the DTAA of Nepal with India, Pakistan and Sri Lanka is shown in the table below. Please refer desktop version for more clarity.
A detailed version of DTAA with India can be found
| Article | China | Thailand | Qatar |
| Dual Residency | Permanent Home -- Vital Interests -- Habitual Abode -- nationals -- Mutual Agreement. For companies - Place of Effective management -- mutual agreement | Same | Same |
| Immovable Property | income from Immovable property (not capital gains) taxed in Source Country | Same | Same |
| Business Profits | Profits attributable to PE only to be taxed in the source state. | Same | Same |
| Shipping and Air transport | Profits in international traffic - taxed in the country where place of head office or of effective management of the enterprise is situated. | Profits from aircraft in international traffic - taxed in the country of residence. Profits from operation of ships in international traffic - taxed in the country of source but tax shall be reduced by 50%. Income from containers to be treated as income from ships or aircrafts. | Same as China. Nothing mentioned about income from containers. |
| Dividends | May be taxed by the country of residence. May be taxed by source state, tax shall not exceed 15%. If the dividend is effectively connected with PE, such income is to be taxed under business profits and not dividend income. | Same | Same. but tax in source state shall not exceed 10% in all cases. |
| Interest | May be taxed in both states. Limit for tax in the source state is 10% of the gross amount. Exempt in the source country if derived by central banks, government or political subdivisions. If such interest income is effectively connected with PE, such interest is to be charged as business income | Same, Except limit for tax in the source state is 10% for financial institutions including insurance companies. 15% in all other cases. | Same, Except limit for tax in the source state is 10% in all cases. |
| Royalties | Same as interest, limit for rate for tax in source state is 15%. | Same. | Same |
| Capital Gains | Income from capital gains from immovable property to be taxed in the country of source. i.e. where the asset is situated. Income from capital gains from alienation of PE or Fixed base including movable property to be taxed in the state of source .Income from alienation of ship or aircraft operated in international traffic is taxable only in the state in which the place of head office or of effective management of the enterprise is situated. Gains from the alienation of shares to be taxed in the country where its immovable assets are located. Gains from disposal of shares other than such representing a participation of 25% in a company which is a resident of a contracting state may be taxed in that state .Other capital gains to be taxed in the country where the alienator is the resident (Country of residence) | Capital gain from immovable property to be taxed where the asset is situated. Includes capital gain from disposal of immovable assets of PE also. Gains from transfer of shares or securities can be taxed at either contracting state. Other capital gains to be taxed in the country of residence. | Same as China DTAA. For shares and stocks - may be taxed in the contracting state in which such shares are issued. |
| Independent Personal Services | To be taxed in the country of residence, but, in the following circumstances, taxed in the country of source - a. has fixed base in another country. b. stay in the other country exceeds 183 days or more in any 12 months. | To be taxed in the country of residence, but in the following circumstances, taxed in the country of source. - a) has fixed base in another country for a period of 183 days or more within any 12 month period (Only income from such fixed base). b) his stay in the other state exceeds 183 days in any 12 month period. remuneration is borne by the resident of the other contracting state or is borne by the PE in such contracting state. | Same as DTAA with Ch |
| Dependent Personal Services | Taxed in the country of source. however, in the following conditions taxed in the country of residence. a)not present in another country for more than 183 days in the last 12 months. b)Remuneration is paid by a employer who is not resident of the other contracting state and remuneration is not borne by PE in the other state. Remuneration provided in ships/aircrafts operating in international traffic - country of residence. | Same | Same. |
| Directors Fee | Country of Source | Same. In addition Salary of top level managerial position is also taxed in the state of source. | Same, In addition Salary of top level managerial position is also taxed in the state of source. |
| Artists/Sportsperson | Country of Source/Countries where the services are performed. Income derived by such persons in the other contracting states under a plan of cultural exchange between the governments of both contracting states shall be exempt in the other state. | Same. If the activities are substantially supported by public funds- taxed in the resident country. | Same as DTAA with China. |
| Pensions | Country of Residence.(Except government pensions - see below). If paid under public welfare or social security system - country of source. | Same, except pension or similar remuneration derived by a resident of a contracting state may be taxed in the other contracting state if such payments are borne by the enterprise of that other state or by a PE situated in that state. (Country of Source) | Same, except pension or similar remuneration derived by a resident of a contracting state may be taxed in the other contracting state if such payments are borne by the enterprise of that other state or by a PE situated in that state. (Country of Source) |
| Government Services | Country of Source. However, in the following conditions Country of Residence - a) National of that state. b) did not become resident solely for the purpose of rendering services. Pension paid out of government funds to be taxable only in that state except when the individual is a resident and national of the other contracting state, Country of residence in that case. Doesn't apply to remuneration and pensions w.r.t business conducted by a government of contracting state or LA. | Same | Same |
| Professors, Teachers and Research Scholars. | No tax for 2 years from the date when entered into another contracting state. Teaching, research only in approved institutions and research should only be for public welfare purposes. | Individual resident of a contracting state - visits another contracting state at the invitation of recognized university, college for a period not exceeding 2 years solely for the purpose of teaching or research shall be exempt from tax. Not applicable if research is for private purpose. | Same as Thailand DTAA |
| Students | Following income exempt - a) Payment made by persons outside the state for education purposes. b) Remuneration from employment, grants and scholarships shall be taxed in par with the residents of that state. | Applies to an individual whose visit to another contracting state is solely for the purpose of - a) studying at university or recognized educational institutions. b) securing training to qualify to practice a profession or trade, c) Carrying out research as a recipient of grant, allowance or award from governmental, charitable, religious, scientific, literary organizations. The following incomes shall be exempt from tax. a) remittances from abroad for above purposes. b) Grant allowance or reward. c) income from personal services (employment) provided the income is reasonably necessary for his maintenance and education. | Payment received from abroad by a student, trainee present in the other state solely for the purpose of education or training shall be exempt. individual present as an employee of or under a contract with a resident of other contracting state or as a participant in a program sponsored by the government of the other state for the primary purpose of a) acquiring technical, professional or business experience from a person other than the resident of the state in which he was a resident immediately before or a person other than related to such person or b) studying at a university or recognized institution. income related to personal activities of such persons shall be exempt from tax for 3 years if the aggregate amount is not in excess of US $4000 or equivalent in Qatari Rupees or Nepali Rupees |
| Other Income | May be taxed in both states. | May be taxed in the country of source. | May be taxed in both states. |
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