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HMRC internal manual

Double Taxation Relief Manual

HM Revenue & Customs
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Namibia: double taxation agreement, Article 15 Artistes and Athletes

Notwithstanding anything contained in the present Convention, income derived by public entertainers, such as theatre, motion picture, radio or television artistes, and musicians, and by athletes, from their personal activities as such may be taxed in the territory in which these activities are exercised.