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HMRC internal manual

Double Taxation Relief Manual

HM Revenue & Customs
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Namibia: double taxation agreement, Article 8: Interest

(1) The rate of tax imposed by South West Africa on interest derived from sources within South West Africa by a resident of the United Kingdom who is subject to tax in the United Kingdom in respect thereof shall not exceed 20%.

(2) The provisions of paragraph 1 of this Article shall not apply if the recipient of the interest being a resident of the United Kingdom has in South West Africa a permanent establishment with which the indebtedness in respect of which the interest arises is effectively connected.

(3) Where, owing to a special relationship between the payer and the recipient or between both of them and some other person, the amount of the interest paid, having regard to the indebtedness in respect of which it is paid, exceeds the amount which would have been agreed upon by the payer and the recipient in the absence of such relationship, the provisions of this Article shall apply only to the last-mentioned amount. In that case, the excess part of the payments shall remain taxable according to the law of South West Africa, due regard being had to the other provisions of the present Convention.

(4) In this Article, the term `interest` means income from Government securities, from bonds or debentures, whether or not secured by mortgage, or from any other form of indebtedness, as well as all other income assimilated to income from money lent by the taxation law of South West Africa.