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HMRC internal manual

Double Taxation Relief Manual

HM Revenue & Customs
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Namibia: double taxation agreement, Article 13: Independent personal services

Income derived by a resident of one of the territories in respect of professional services or other independent activities of a similar character shall be subjected to tax only in that territory unless he has a fixed base regularly available to him in the other territory for the purpose of performing his activities. If he has such a fixed base, such part of that income as is attributable to that base may be taxed in that other territory.