In defence of Nepal

The dispute between Axiata (and Ncell) and Nepal revolves around purported treaty breaches.

#NoTaxNoNcell. This hashtag resonated strongly in 2015 when the profits earned in the single largest share purchase transaction in Nepal’s corporate history were not subjected to taxes. It pressed hard for more scrutiny and audits by the parliamentary committees and the auditor general, and included demands for recovery of taxes through public interest suits filed before the Supreme Court. The deal to secure the purchase of Ncell, one of the duopoly telecom service providers incorporated in Nepal, was structured through the acquisition of 100 percent share capital of Ncell’s immediate holding company Reynolds Holdings Ltd, incorporated in St Kitts and Nevis, a country infamously known for the low taxation offered to businesses. Malaysian company Axiata Group Berhad, through its United Kingdom subsidiary Axita UK, purchased Reynolds from Telia’s subsidiary established in Norway. The purchase price paid after the completion of the transaction on April 11, 2016 as per Axiata’s public disclosure was $1.365 billion.