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HMRC internal manual

Double Taxation Relief Manual

Namibia: double taxation agreement, Article 12: Pensions

(1) Any pension (other than a pension of the kind referred to in paragraph (2) of Article 11) and any annuity, derived from sources within South West Africa by an individual who is a resident of the United Kingdom and subject to United Kingdom tax in respect thereof, shall be exempt from South West African tax.

(2) Any pension (other than a pension of the kind referred to in paragraph (2) of Article 11) and any annuity, derived from sources within the United Kingdom by an individual who is a resident of South West Africa and subject to South West African tax in respect thereof, shall be exempt from United Kingdom tax.

(3) The term `annuity` means a stated sum payable periodically at stated times, during life or during a specified or ascertainable period or time, under an obligation to make the payments in return for adequate and full consideration in money or money’s worth.