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HMRC internal manual

Double Taxation Relief Manual

From
HM Revenue & Customs
Updated
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Namibia: double taxation agreement, Article 7: Undistributed profits tax

(1) A company which is a resident of the United Kingdom shall be exempt from undistributed profits tax in South West Africa for any year of assessment:

  1. if on the last day of that year of assessment residents of the United Kingdom control, directly or indirectly, more than 50% of the entire voting power of the company; or
  2. if the company is not during that year of assessment a private company registered or carrying on business in South West Africa; or
  3. if the company can show that not more than 50% of its total net profits for that year of assessment was derived from sources within South West Africa.

(2) Where a company which is a resident of the United Kingdom is not exempt from undistributed profits tax in South West Africa for any year of assessment, the amount of that tax chargeable for that year of assessment shall be reduced by an amount which bears to the tax that would, but for the provisions of this Article, be payable for that year the same ratio as that portion of the distributable income for that year which the company shows to the satisfaction of the South West African taxation authorities would not, if the distributable income were in fact distributed, accrue directly or indirectly to residents of South West Africa bears to the full amount of such distributable income.