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HMRC internal manual

Double Taxation Relief Manual

Namibia: double taxation agreement, Article 26: Termination

(1) The present Convention shall continue in force indefinitely, but either of the Contracting Parties may, on or before 30th June in any calendar year not earlier than the year 1966, give to the other Contracting Party, through diplomatic channels, written notice of termination and, in such event, this Convention shall cease to be effective -

  1. In South Africa:

    as respects taxes on income, for any year of assessment ending after 30th June in the calendar year next following that in which the notice is given; and

    as respects non-resident shareholders’ tax, on dividends declared after 30th June in the calendar year next following that in which the notice is given;

  2. in the United Kingdom:

    as respects income tax, for any year of assessment beginning on or after 6th April in the calendar year next following that in which the notice is given;

    as respects surtax, for any year of assessment beginning on or after 6th April in the calendar year in which the notice is given; and

    as respects profits tax, for any chargeable accounting period beginning on or after 1st January in the calendar year next following that in which the notice is given and for the unexpired portion of any chargeable accounting period current at that date.

(2) The termination of this Convention shall not have the effect of reviving any agreement or arrangement abrogated by the present Convention or by any agreement previously concluded between the Contracting Parties.