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HMRC internal manual

Double Taxation Relief Manual

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HM Revenue & Customs
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Namibia: double taxation agreement, Article 20: Elimination of double taxation

(1) Subject to the provisions of the law of the United Kingdom regarding the allowance as a credit against United Kingdom tax of tax payable in a territory outside the United Kingdom, South West African tax payable, whether directly or by deduction, in respect of income from sources within South West Africa shall be allowed as a credit against any United Kingdom tax payable in respect of that income. Where such income is a dividend paid by a company which is a resident of South West Africa to a company which is a resident of the United Kingdom which controls directly or indirectly not less than one-tenth of the voting power in the former company, the credit shall take into account (in addition to any South West African tax payable in respect of the dividend) the South West African tax payable by that former company in respect of its profits.

(2) Where United Kingdom income tax is payable, whether directly or by deduction, in respect of income derived from sources within the United Kingdom by a resident of South West Africa, and that tax is borne by him, South West Africa shall either impose no tax on that income or, subject to such provisions (which shall not affect the general principle hereof) as may be enacted in South West Africa, shall allow the United Kingdom tax as a credit against any South West African tax payable in respect of that income; provided that, where the income is a dividend received from a company which is a resident of the United Kingdom, nothing in this paragraph shall require credit to be allowed at a rate in excess of the net United Kingdom rate borne by the company.

(3) For the purposes of this Article, remuneration for personal (including professional) services performed in one of the territories shall be deemed to be income from sources within that territory, and the services of an individual whose services are wholly or mainly performed in ships or aircraft operated by a resident of one of the territories shall be deemed to be performed in that territory.