With regard to the 2016 ratification law on international conventions (the law), the DBA falls under the category of “bilateral treaties” and does not require ratification by Parliament, unlike “international agreements”. It is therefore not necessary to ask Parliament to terminate the treaty. The termination procedure defined by the DBA itself applies. Due to the rules of source and dividend-exempt status, only a few items subject to foreign tax are subject to Namibian tax. There is no general unilateral provision for the exemption from double taxation, although a specific provision prevents double taxation of royalties. In the event that Namibia has a double taxation agreement (DBA) with the country in which the foreign residence resides, that person is taxable in Namibia, unless all the specific DBA requirements are met. It is not uncommon for a company or person established in one country to make a taxable profit (profits, profits) in another country. This person may find that under national laws, he or she is required to pay taxes on that profit on the spot and to pay again in the country where the profit was made. As this approach is unfair, many nations enter into bilateral double taxation agreements.
In some cases, the tax is paid in the country of residence and exempted in the country where it is created. In other cases, the country where the profit is generated is deducted from the withholding tax (“withholding tax”) and the taxpayer receives a compensatory tax credit in the country of residence to take into account the fact that the tax has already been paid. To do so, the taxpayer (abroad) must declare himself non-resident. A double taxation contract can, in principle, compensate for the tax paid in one country by the tax payable in the other and thus avoid double taxation. In addition, Australia and Mauritius have signed a tax and information exchange agreement. The following areas have contracts with Mauritius, but the treaties are awaiting ratification: the DBA between Zambia and Mauritius requires the contracting parties to terminate the termination by 30 June of the calendar year, provided that the contract has been in force for at least five years. Once the notice is issued, the contract will no longer apply to Zambia on the last day of the calendar year and to Mauritius on July 1 of the following calendar year.