Core rule: section 67 looks at the activity generating employment income. Pay for work performed in Nepal is Nepal-source, even when the employer and receiving bank are abroad. Residence separately determines whether worldwide assessable income is taxable in Nepal.
Example: an employee works from Kathmandu for a private overseas employer and is paid into a foreign account. The foreign account does not turn those Nepal-performed duties into foreign-source employment.
An assignment physically performed abroad requires a different source analysis; a Nepal resident may still be taxable on that foreign income. Special government-employment rules and an applicable treaty must also be considered.
Establish whether the relationship is employment or an independent service business. Do not automatically apply a special foreign-currency service collection rate to every overseas salary receipt. Keep contracts, work-location records and gross-pay details.