The 1996 France-Namibia tax treaty: income and wealth, article by article

The administration's list classifies the France-Namibia convention among those concerning income and wealth. It caps withholding tax at 5 or 15 on dividends and at 10 on interest and royalties (excluding copyright).

A text from 1996, in force since May 1, 1999

Signed in Windhoek on May 29, 1996, the convention entered into force on May 1, 1999. List BOI-ANNX-000306 (April 29, 2026) does not indicate any amendments. Application (Article 30). France: withholding tax on taxable amounts from January 1, 2000, other income taxes for periods beginning on that date, and wealth tax from that date. Namibia: same date for withholding tax and wealth tax, March 1, 2000 for other income taxes.

Maximum deductions and key rules

Wealth: a separate article

In addition to the rules outlined in the table, Article 22 makes a substantial shareholding (the right to at least 25% of the company's profits) taxable in the company's state and attributes the assets of a permanent establishment to that establishment. Its application to the French wealth tax (IFI) is not established by the sources consulted.

The list of Namibian taxes in Article 2 § 3 (normal income tax, tax on dividends of non-resident shareholders, tax on petroleum income) does not mention any wealth tax, whereas the administrative list classifies the convention among those on income and wealth: to be verified in the text, the page does not decide.

Residence and deadlines

Article 4 determines the eligibility of a natural person resident in both States based on: permanent home, center of vital interests, habitual residence, nationality, and then agreement of the competent authorities. The amicable procedure lasts three years from the first notification (Article 25, paragraph 1). Article 31 allows for termination after a period of five calendar years, provided that notice is given through diplomatic channels at least six months before the end of a calendar year.

Eliminate double taxation

In France, Article 23 grants a tax credit equal to the Namibian tax, capped at the corresponding French tax. Namibia deducts French income and wealth tax, up to the limit of its own corresponding tax.

Dividends and royalties: typical case (fictitious profile)

Situation. A French company (fictitious profile) receives €50,000 in gross dividends from a Namibian company, without holding 10% of its capital, and €80,000 in gross royalties from a Namibian licensee. Assumption: these royalties do not relate to copyright or a similar right.

Issue. She is looking for the maximum tax that Namibia can withhold at source.

Strategy. It applies Articles 10 § 2 and 12 § 2.

Result. Dividends: €7,500 (15 %), compared to €2,500 (5 %) if she held at least 10 % of the capital. Royalties: €8,000 (10 %). These figures are maximums, not the tax due.

What this page does not cover

Namibian tax rates and information exchange procedures are not detailed. The administrative list does not include any text on inheritance.

What changes depending on your situation

• Your residence as defined in the agreement.
• The nature of the income.
• The percentage of capital held and the nature of your assets.
• The number of days spent in each state over twelve months.

An article should be read in light of the facts in your case, and no result is guaranteed in advance.