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HMRC internal manual

Double Taxation Relief Manual

From
HM Revenue & Customs
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Namibia: double taxation agreement, Article 11: Governmental functions

(1) Remuneration (other than pensions) paid by one of the Contracting Parties to any individual for services rendered to that Contracting Party in the discharge of governmental functions shall be exempt from tax in the territory of the other Contracting Party if the individual is not ordinarily resident in that territory or is ordinarily resident in that territory solely for the purpose of rendering those services.

(2) Any pension paid by one of the Contracting Parties to any individual for services rendered to that Contracting Party in the discharge of government functions shall be exempt from tax in the territory of the other Contracting Party, in so far as the remuneration for those services was exempt from tax in that territory under paragraph (1) of this Article or would have been so exempt of the present Convention had been in force at the time when the remuneration was paid.

(3) The provisions of this Article shall not apply to payments in respect of services rendered in connection with any trade or business carried on by either of the Contracting Parties or purposes of profit.