Nepal Issues Longstanding Notification To Seven Tax-Treaty Partners

On 12 November 2025 (26 Kartik 2082), the Government of Nepal issued its first formal notification under Section 3(4) of the Income Tax Act 2002 ('ITA 2002') to seven countries with which Nepal has pre-2002 Double Taxation Avoidance Agreements ("DTAAs"). The notification, transmitted through the Ministry of Foreign Affairs on behalf of the Inland Revenue Department ("IRD"), was sent to Norway, Thailand, Sri Lanka, Austria, Pakistan, China, and South Korea. This action is grounded in requirement under each respective agreements that Nepal inform treaty partners about domestic tax provisions that may affect treaty application. But this notification was delayed by no less than 24 years.

Although ITA 2002 requires Nepal to inform treaty partners about domestic tax provisions that may affect treaty interpretation or application, this statutory requirement had remained unfulfilled since 2002. There were originally eight pre-2002 DTAAs. The Nepal–Mauritius DTAA was terminated on 28