What kind of organization is this that benefits from government decisions? And what are the reasons why the government's decisions are controversial?
The interim government, which has been given a mandate to hold elections within six months, has been embroiled in controversy after it decided to grant income tax exemptions to companies that invested in Nepal through a "shell company" in the "tax haven country" of Mauritius.
Why did the government decide to grant tax exemption to Dolma Impact Fund, which has invested in 16 companies in Nepal, on the proposal of Finance Minister Rameshwar Khanal? What kind of organization is this that will benefit from the government decision? And why is the government's decision controversial? We have tried to explain in five questions and answers.
What kind of organization is Dolma Impact Fund, which will benefit from the government's decision to grant tax exemption?
Dolma Impact Fund is a company registered in Cyber City, Mauritius, with its office at Mayawa Tower. In countries like Mauritius, where there is little scrutiny regarding the transparency of investment sources and the identity of investors, it is common to open a company in various countries and invest in various countries through it. Therefore, investors from different countries open 'shell companies' in countries like Mauritius, Panama, British Virgin Islands, Cayman Islands, Bahamas and invest in various countries through it as direct foreign investment. For this, cell (shell) companies are registered in such countries. It has been active in Nepal since 2003.
Where and how did the investment coming to Nepal through Dolma Impact Fund come from?
Only 0.75 percent of the investment in Dolma Impact Fund is from Mauritian citizens. The remaining 99.25 percent of the investment was brought to Nepal by taking the same amount to the company in Mauritius from various countries. Mauritius is known as a tax haven country. 100 percent of the investment in this company is Development Finance Institutions (DFIs). DFI is institutional money collected from developed countries. Based on this, there is no private investment in Dolma. It has brought investment to Nepal from all the developed countries that have relations with Nepal. The main countries that have invested in this company include Swiss funds, Japan, UK, Netherlands, America, etc.
How much has Dolma Impact Fund invested in Nepal in what areas?
Dolma Impact Fund has brought investment to Nepal in various phases. Phase 1 has brought in 36.6 million (about 5 billion) and Phase 2 has brought in 71.96 million US dollars (about 10 billion). Of the first phase amount, about 27 billion US dollars of investment has been approved. Most of the second phase amount is in the process of coming in, while only a few have been invested. This company has invested in various sectors including health, hydropower, information technology, startups.
Dolma has investments in Cloud Factory Holdings, DOS Pharmaceuticals, Fuse Machines, Makar Jitumaya Suri Hydropower, Nidan Hospital, Sasto Deal, Solar Farm, Shweta Ganga Hydropower and Construction, Upay City Cargo, Foodmand, Worldlink, Setikhola Hydropower, Chirayu Hospital, Century Masala, National Pathlabs and Research Center, and Rhododendron Biotech.
Why did the government's decision become controversial?
The cabinet meeting held on Kartik 12 decided to revoke the double taxation agreement with Mauritius. A double taxation agreement was signed between Nepal and Mauritius on October 3, 1999. Now the government has resorted to the same agreement to give tax exemption to the same Dolma Fund. Dolma's investment is to earn profit. If the shares of those companies are sold at a higher price than before, capital gains tax should be levied. But capital gains tax has been made non-taxable by showing the agreement. Tax administration experts have been saying that tax exemption cannot be given on the basis of the agreement since the investment is made in companies that have opened offices and operated in Nepal and have the aim of making profit. They have been arguing that taxes should be levied according to the provisions of the Income Tax Act 2058.
What will be the loss to Nepal if this decision is implemented?
It is not possible to say for sure how much loss the government will suffer from this decision. Because the full text of the decision has not been made public yet. It is also not clear whether all of Dolma's investments will be taxed or just some of them. Director General of the Internal Revenue Department, Madan Dahal, has said that it has now been decided to exempt capital gains tax on the sale of shares in Makar Jitumaya Suri Hydropower. Dolma wants to sell its shares in this company. Even if the shares are sold, the government will lose about 29.5 million rupees at the current price. If the government decides to exempt all of Dolma's investments so far, Nepal will lose millions of rupees in tax that it receives according to the law.
