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HMRC internal manual

Double Taxation Relief Manual

HM Revenue & Customs
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Namibia: double taxation agreement, Article 25: Entry into force

(1) The present Convention shall be ratified by the Contracting Parties in accordance with their respective constitutional and legal requirements.

(2) The instruments of ratification shall be exchanged at London as soon as possible.

(3) Upon exchange of the instruments of ratification this Convention shall enter into force and its provisions shall have effect-

  1. in South West Africa:
as respects taxes on income, for any year of assessment ending after 30th June, 1962; and   

as respects non-resident shareholders' tax, on dividends declared after 30th June, 1962;   
  1. in the United Kingdom:
as respects income tax, for any year of assessment beginning on or after 6th April, 1962;   

as respects surtax, for any year of assessment beginning on or after 6th April, 1961; and   

as respects profits tax, for any chargeable accounting period beginning on or after 1st January, 1962, and for the unexpired portion of any chargeable accounting period current at that date.   

(4) The Agreement between South Africa and the United Kingdom of Great Britain and Northern Ireland, signed at London on 14th October, 1946 together with the Supplementary Protocol amending that Agreement signed at Pretoria of 5th November, 1954, shall terminate and cease to be effective as respects taxes to which this Convention in accordance with paragraph (3) above applies; provided that the said Agreement and Supplementary Protocol shall still apply as between South Africa and those territories to which that Agreement and Supplementary Protocol have been extended under Article 15 of the Agreement.