Nepal is in DTAA agreement with 11 different countries. A short comparative study of the DTAA of Nepal with Norway, Mauritius and Korea is shown in the table below. Please refer desktop version for more clarity.
A detailed version of DTAA with India for your reference can be found
| Article | Norway | Mauritius | Korea |
| 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 country of Residence. Profits from containers - Taxed in the country of Residence except when solely used in the country of source. | Profits from ships, containers - Where place of effective management is situated. If such place is aboard a ship or boat - Place where home harbor of the ship is located. If no home harbor - Country of Residence | Profits from ships aircrafts in international traffic - country of residence. Not mentioned about containers. |
| Dividends | May be taxed by the country of residence. May be taxed by source state, tax so charged shall not exceed. a) 5% of the gross amount if the beneficial owner is a company which holds directly at least 25% of the shares of such company. b) 10% if holds at least 10%, c) 15% in other cases. | May be taxed by the country of residence. May be taxed by source state, tax so charged shall not exceed. a) 5% of the gross amount if the beneficial owner is a company which holds directly at least 15% of the shares of such company. b) 10% if holds at least 10%, c) 15% in other cases. | May be taxed by the country of residence. May be taxed by source state, tax so charged shall not exceed. a) 5% of the gross amount if the beneficial owner is a company which holds directly at least 25% of the shares of such company. b) 10% if holds at least 10%, c) 15% in other cases. |
| Interest | May be taxed in both states. Limit for tax in the source state is 15% of the gross amount and 10% for banking business (Only banking is mentioned). Exempt in the source country if derived by central banks, government or political subdivisions or a loan guaranteed by such institutions. If such interest income is effectively connected with PE, such interest is to be charged as business income | May be taxed in both states. Limit for tax in the source state is 10% for financial institutions, insurance, investment companies. Exempt in the source country if derived by central banks, government or political subdivisions or a loan guaranteed by such institutions. If such interest income is effectively connected with PE, such interest is to be charged as business income | May be taxed in both states. Max limit for source country is 10% in all cases. Exempt in the source country if derived by central banks, government or political subdivisions or a loan guaranteed by such institutions. If such interest income is effectively connected with PE, such interest is to be charged as business income |
| 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 income from Shipping or aircraft under article 8 is taxable. Gains from alienation of containers are taxable in resident state except when they are solely used in the source state. Gains from the alienation of other immovable assets are taxable in the resident country | 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 where the place of effective management is situated. Other Capital gains - Country of Residence. | 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 of residence. Gains from alienation of shares - where the immovable property are principally situated. |
| 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. | Same | Same |
| 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 - as per article 8 shipping and air transport. | Same | Same |
| Directors Fee | Country of Source | Same. Also top level managerial position also in the country of source | Country of Source |
| Artists/Sportsperson | Country of Source/Countries where the services are performed. If such visit to another state is substantially supported by public funds of other contracting state or LA or political subdivision - country of residence | Same. Activities performed under a cultural agreement or arrangement between the Contracting States shall be exempt from tax in the Contracting State in which the activities are exercised if the visit to that State is wholly or substantially supported by funds of either Contracting State, a local authority or public institution thereof. | Country of Source/Countries where the services are performed. If such visit to another state is under a special program of cultural exchange - exempt in source country. |
| Pensions | Country of Residence.(including government pensions and pensions under social security schemes). | Country of Residence (excluding government pensions). Pension under social security scheme - State of Source. | Country of Residence (excluding government pensions). Pension under social security scheme - State of Source. |
| Government Services | Remuneration other than pension - 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. c) services are performed in that state. Doesn't apply to remuneration (except pensions - pension is taxed under article 18 ) w.r.t business conducted by a government of contracting state or LA. | Salaries, wages, and other similar remuneration -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. c) services are performed in that state. 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. | Same as Mauritius |
| Professors, Teachers and Research Scholars. | Not Mentioned | 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. | 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. |
| 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, The limitations w.r.t length of stay if any shall apply. | Payments received by students from outside the contracting state for the purpose of education 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. | Student or business apprentice - present in the other contracting state solely for the purpose of his education or training, shall be exempt from tax in the source state - a) payments from abroad for maintenance, education or training. b) Remuneration from employment - $10,000 or its equivalent provided such employment is directly related to his studies or is undertaken for the purpose of his maintenance. |
| Other Income | May be taxed in both states. | May be taxed in both states | May be taxed in the country of residence. |
| Capital | Capital related to Immovable property - Where asset is situated. Capital related to movable property of PE or Fixed base - Where PE is located (Source). Capital represented by Shipping and Aircraft - where income is taxed as per article - 8. Containers - country of residence, except when used solely between places within the other contracting state | Not Mentioned | |
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