'Dolma is here to Show that Nepal can be a Global Success Story for Responsible Investment'

Tim Gocher OBE, chief executive of Dolma Fund Management, has spent the past decade trying to prove that Nepal can attract large-scale, responsible international capital. Managing over $100 million through Dolma Impact Fund I and II—the country’s largest foreign private equity vehicles—Dolma invests across renewable energy, healthcare, and technology, supporting more than 10,000 jobs. Recently, Dolma found itself at the center of public debate after an interim government decision to grant a tax exemption in relation to its share sale in Makar Jitumaya Suri Hydropower Pvt Ltd. The government decision was based on the Nepal–Mauritius Double Taxation Avoidance Agreement (DTAA). In this interview with Akhilesh Tripathi, Gocher speaks candidly about regulatory unpredictability, tax certainty, repatriation hurdles, and the reforms Nepal urgently needs if it is to convert its vast potential into sustained foreign investment. Excerpts:

How predictable and investor-friendly is Nepal’s regulatory environment today? Based on Dolma’s rience, which aspects  of the investment climate—such as legal clarity, license renewals, taxation, and dispute resolution—create the greatest  uncertainty for long-term investors?

Nepal offers tremendous potential for foreign investment, and Dolma was established to demonstrate that potential and encourage responsible capital to flow into the country in support of economic prosperity. Our experience shows that while policy intent is generally positive,  the regulatory environment remains  uneven in practice. Investors continue to face delays and inconsistencies in approvals from key agencies,  with processing timelines  varying widely and often  extending far beyond the three-month period envisaged in law. One of Dolma’s own approvals took more than 13 months. Such delays undermine predictability for long-term capital.

There are also structural issues, including the requirement to complete a transaction before repatriation approval is granted, which exposes investors to unnecessary  IRR risk if approvals are delayed. While the broader legal framework is sound,  its interpretation varies across institutions—particularly in taxation, repatriation, licensing, and contract enforcement. Strengthening regulatory clarity, consistency, and time-bound administration would significantly enhance investor confidence at a time when  Nepal urgently needs to attract greater volumes  of foreign  capital to meet its development goals.

How cooperative and predictable is Nepal’s tax administration in practice? Have sudden changes in tax assessments or retrospective interpretations ever affected your business decisions?

Dolma has great respect for Nepal’s tax authorities and works constructively with them. However, unpredictability remains  a significant challenge.  Sudden  shifts in interpretation, retrospective positions, and inconsistent application of existing provisions  have created uncertainty—particularly in the area of cross-border taxation. We welcomed the government’s recent clarification on the Nepal–Mauritius DTAA, which correctly applied both the treaty and the Treaty Act. Predictability in tax administration is critical for attracting foreign capital, and greater certainty around issues such as withholding tax exemptions, international borrowing, and treaty interpretation would materially strengthen Nepal’s investment climate.

What specific bureaucratic bottlenecks do foreign investors face when operating in or expanding their businesses in Nepal?

A: Foreign investors frequently encounter bottlenecks. Applications  for investment approvals, reinvestment, loan registration, and share  transfers often  pass through multiple agencies with limited coordination, and there is no unified digital platform  to track progress. Processing timelines  vary widely depending on the reviewing  officer, and procedures often  restart when  responsibilities shift internally. In the energy  sector—now a major focus for international capital—uncertainty around PPA enforcement, compensation mechanisms, potential Nepal Electricity Authority (NEA) default events, and dispute-resolution procedures further complicates investment decisions. While these challenges do not diminish Nepal’s underlying potential, addressing them would significantly accelerate foreign direct investment inflows.

How difficult is it to repatriate profits and dividends under Nepal’s current approval system? What reforms would make the process more transparent and time-bound?

Repatriation is legally permitted in Nepal, but in practice the process can be lengthy and unpredictable. One of the most significant challenges is that investors must complete  the sale, transfer title, and pay applicable  taxes before they can even apply for repatriation approval.  This sequencing exposes sellers to material financial risk if approvals are delayed,  despite the transaction having already closed.

A more transparent and time-bound system would significantly improve  investor confidence. Introducing a digital single-window approval mechanism, standardizing documentation requirements, and enforcing statutory response timelines  would make the repatriation process smoother and more predictable.

Has regulatory uncertainty affected your willingness or ability to reinvest profits in Nepal? What policy or procedural changes would meaningfully encourage reinvestment?

Dolma remains  deeply  committed to Nepal and has already helped  create more than 12,000 jobs, primarily for young Nepali people. Our mission is to demonstrate that Nepal can become a success story by showing that the country honors its laws, treaties, and international norms. At the same time, regulatory unpredictability does  influence reinvestment decisions—not only for Dolma, but for the wider global investment community observing Nepal’s trajectory. Unclear tax practices, delayed  approvals, restrictive loan conditions such as capped interest rates on NPR-denominated loans, and high taxes on international borrowing all affect investment appetite. Nepal’s renewable-energy roadmap alone requires more than $48 billion in investment, and mobilizing this capital depends on a stable and predictable policy environment. Reforms that strengthen regulatory clarity, accelerate approvals, modernize energy-sector contracts, and reduce the cost of international financing would significantly encourage reinvestment.

If you could advise Nepal’s government on three urgent reforms to attract and retain serious foreign investors, what would they be?

Nepal would benefit greatly from reforms that are both achievable in the near term and highly impactful for foreign direct investment. The first priority is a clear, consistently applied tax-certainty framework that fully reflects Nepal’s treaty obligations and prevents disputes before they arise. The second is a time-bound, digital single-window mechanism for FDI approvals, loan registrations, repatriation, and renewals, ensuring  that routine processes do not drag on for months—or even more than a year, as sometimes happens today. The third is to strengthen the investment ecosystem in priority sectors by modernizing power purchase agreements (PPAs), clarifying termination and compensation provisions, enabling step-in rights for lenders, and reducing  financing bottlenecks such as interest-rate caps and high withholding taxes on international loans. Taken together, these reforms would send a strong signal that Nepal is ready to attract and absorb investment at scale. 

Are there global best practices—tax certainty, fast-track approvals, independent dispute resolution—that Nepal should consider adopting?

Countries that have successfully attracted long-term foreign investment, such as Mauritius,  Singapore,  Rwanda, and India, emphasize predictability, regulatory clarity, fast-track approvals, and neutral dispute-resolution mechanisms. Mauritius,  where Dolma is regulated as a private equity fund, is a useful example of a transparent and internationally trusted financial jurisdiction  that provides strong governance, compliance, and treaty-based investor protection. Nepal can adopt similar practices by ensuring advance tax rulings that integrate domestic law and treaty obligations, implementing automatic or fast-track approval  routes, enabling lenders to exercise step-in rights, and allowing neutral arbitration forums  in PPAs and major contracts. These steps would align Nepal with international norms and create confidence for global investors.

There has been public discussion around the government’s recent decision involving Dolma and capital gains tax under the Nepal–Mauritius tax treaty. Was any tax waiver granted to Dolma, and how should this decision be understood?

Dolma wishes to clarify unequivocally that no tax waiver was granted. Dolma has never exited an investment in Nepal, and therefore no capital gains tax has ever arisen. The government’s recent decision  concerned a clarification on how the Nepal–Mauritius DTAA applies, and it correctly reaffirmed Nepal’s legal obligations under  the Treaty Act, which gives treaty provisions priority where inconsistencies exist. The treaty allocates the right to tax share-sale gains exclusively to the country of residence, which in Dolma’s case is Mauritius.  The DTAA contains no limitation-of-benefits clause, and Section  73 of the Income Tax Act does  not apply to treaties signed prior to 2002,  such as the Nepal–Mauritius agreement. We are grateful to the government for applying the law correctly. We hope  this clarity sends  a positive  and reassuring signal to the international investment community, many of whom closely follow Dolma’s experience to inform their own decisions about Nepal.

What message does Dolma’s continued presence in Nepal send to international investors assessing the country’s long-term prospects?

Dolma exists to show that Nepal can be a global success story for responsible investment. Our work is grounded in the belief that by operating transparently, honoring both Nepali and international law, and investing  in companies that create jobs and opportunity, Nepal can unlock transformative economic growth. Nepal faces vast opportunities, particularly in clean energy,  and attracting the necessary capital requires a predictable, transparent, efficient regulatory environment. We stand ready to continue investing, creating jobs, and supporting Nepal’s development while advocating for reforms that benefit both investors and the country.

(This interview was originally publsihed in January 2026  issue of New Business Age magazine.)