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HMRC internal manual

Double Taxation Relief Manual

Double Taxation Relief Manual: Guidance by country: Namibia: Dividends

The Namibian tax deducted from dividends paid by a Namibian company at the rates of 12 per cent (the agreement provides for a rate not exceeding 15 per cent), or 5 per cent where the recipient is a United Kingdom resident company controlling, directly or indirectly, more than 50 per cent of the entire voting power in the company paying the dividend, qualifies for credit as a direct tax (see INTM164010(c)) (Article 6(l)).

The reduction to the above rates is not given if the dividend is effectively connected with (see INTM153110 fifth sub-paragraph) a permanent establishment which the recipient has in the United Kingdom (Article 6(3)).

Note also the following

  1. See the guidance in DT17354 as regards the allowance of credit where the paying company is incorporated in the United Kingdom;
  2. The Namibian tax on dividends is chargeable only on the proportion of the dividend which is attributable to the net profit derived in Namibia. The rate at which tax is withheld from dividends may, therefore, in some cases be less than the nominal rates of 12 per cent and 5 per cent.

Whether the recipient of the dividend is a United Kingdom company controlling, directly or indirectly, not less than 10 per cent of the voting power in the Namibian company paying the dividend, credit may also be given for the underlying tax (see INTM164010 (d)) (Article 20(l)).