IRD Nepal Archives - Shankar Associates

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Nepal’s Safe Harbour Rule: A Simpler Approach to Transfer Pricing

The Finance Bill 2083 has brought in the “Safe Harbour Rule” provision within the context of Nepali Income Tax law. This rule allows taxpayers to bypass complex transfer pricing documentation and benchmarking studies by adhering to predefined margins or rates, provided they meet specific criteria.

By Shankar Thapa, 4 monthsJune 10, 2026 ago

Advisory & Insights

The Database Gap: Why Nepal’s Transfer Pricing Directive 2024 Has a Data Problem — and What to Do About It

Nepal’s Transfer Pricing Directive 2024 introduces a rigorous benchmarking framework — but cites data sources that are practically inaccessible to taxpayers. Until domestic financial disclosure laws are reformed, practitioners must rely on commercial databases like Prowess IQ and AceTP. Here is what you need to know.

By Shankar Thapa, 5 monthsMay 26, 2026 ago