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HMRC internal manual

Double Taxation Relief Manual

Namibia: double taxation agreement, Article 24: Territorial extension

(1) The present Convention may be extended either in its entirety or with modifications, by agreement between the Contracting Parties, to all or any of the territories for whose international relations either Contracting Party is responsible and which impose taxes substantially similar in character to those which are the subject of this Convention, and any such extension shall take effect from such date and subject to such modification and conditions (including conditions as to termination) as may be specified and agreed between the Contracting Parties in Notes to be exchanged for this purpose.

(2) The termination in respect of South West Africa or the United Kingdom of this Convention under Article 26 shall, unless otherwise expressly agreed by both Contracting Parties, terminate the application of this Convention to any territory to which the Convention has been extended under this Article.