Namibia’s NIPDB and PwC Namibia have released the fifth edition of the Namibia Investment Guide, outlining corporate tax rates and incentives, foreign investment rules, VAT, customs, transfer pricing, and other key tax and compliance requirements for businesses and investors.
The Namibia Investment Promotion and Development Board (NIPDB) released the Namibia Investment Guide: Tax Laws in Namibia, Volume 5, on 4 September 2026, detailing the tax laws, compliance framework, and financial regulations governing investors and entities in Namibia. It details the obligations for various taxpayers, including corporations, individuals, and non-residents, while clarifying the role of the Namibian Revenue Agency (NamRA).
Volume 5 of the Namibia Investment Guide was developed jointly by the Namibia Investment Promotion and Development Board (NIPDB) and PwC Namibia.
Tax system and income tax
Namibia applies a source-based tax system under the Income Tax Act, 1981, with taxable income generally based on Namibian-source gross income, less allowable expenses and capital allowances.
Wear-and-tear allowances are spread over three years, while buildings receive a 20% initial allowance followed by 4% annually for 20 years. Namibia generally has no capital gains, estate duty, donations, or wealth taxes.
From 2024, loss carry-forwards are limited to NAD 1 million or 80% of taxable income, with periods of 10 years for mining, petroleum and green hydrogen and five years for others. Thin-capitalisation rules limit interest deductions where net interest exceeds 30% of tax EBITDA and NAD 3 million.
Tax administration
Taxes, duties, and customs are administered by the NamRA, established in 2017. Its main directorates oversee large taxpayers and investigations, small and medium taxpayers through 7 regional divisions, tax administration and support services, and customs and excise operations, including border controls, clearances, tariffs, and trade compliance.
Taxation of corporations
The standard corporate tax rate for non-mining and general companies is 30% from financial years beginning 1 January 2025.
Rates are 37.5% for non-diamond mining, 55% for diamond mining, and 35% for petroleum production, with additional petroleum profit tax. Long-term insurers are taxed at 12% on 40% of gross investment income.
A 20% SEZ rate has been proposed, while legacy EPZ and manufacturing tax incentives have been repealed.
Taxation of foreign corporations
Foreign businesses operating through a local presence must establish a branch or subsidiary, with branches generally taxed at standard rates on Namibian-source income. Under DTAs, taxation generally depends on the existence of a Permanent Establishment (PE).
WHT rates include 10% on dividends where foreign ownership exceeds 25%, 20% otherwise, and 10% on interest, royalties, know-how, and management/administrative/consulting services. Foreign directors’ fees are subject to 25% WHT, with no DTA relief.
Taxation of shareholders
Dividends received by local shareholders have historically been tax-exempt, although a 10% local dividend tax has been proposed.
Non-resident dividends are subject to 10% or 20% NRST. Long-term investment share disposals are generally non-taxable, but gains from shares in entities holding mining or petroleum rights are taxed at the corporate rate.
Unlisted share transfers attract stamp duty of NAD 2 per NAD 1,000 of consideration or market value.
Taxation of partnerships and joint ventures
Partnerships, unincorporated joint ventures, syndicates, and consortiums are not separate taxable entities. Profits and losses pass through to the partners or venturers, who report their respective shares. However, these entities must separately comply with VAT, PAYE, and withholding tax requirements where applicable.
VAT
Namibia applies a standard 15% VAT, with qualifying supplies zero-rated. VAT registration is compulsory when taxable turnover exceeds NAD 1 million over 12 months, while businesses expecting at least NAD 200,000 may register voluntarily.
Import VAT is effectively 16.5% after the 10% FOB uplift. VAT returns are generally filed every two months, and records must be retained for five years. Exempt supplies include financial, medical, educational, and residential rental services.
Customs, excise, and fuel levies
As a SACU member, Namibia applies duty-free trade between member states, while imports from outside SACU are subject to the Common External Tariff. Accredited AEOs receive customs facilitation benefits, including priority clearance and expedited VAT refunds. Fuel prices include various statutory levies, while heavy vehicles over 3,500 kg are subject to Mass Distance Charges. Excise duties apply to products including alcohol, tobacco, fuel, and luxury goods.
Taxation of trusts and estates
Trusts are generally taxed at individual progressive rates. Income from vesting trusts distributed to beneficiaries is taxed on the beneficiaries, while discretionary trust income is taxed at the trust level and later distributions are generally treated as non-taxable capital. Deceased and insolvent estates are subject to separate rules determining whether income is taxed to the deceased, heirs, estate, or insolvent individual.
Export levies & environmental taxes
Export levies apply to certain unprocessed or semi-processed minerals, agricultural products, live animals, and fish/marine products to encourage domestic processing. Environmental levies include carbon charges on vehicles, a NAD 10 tyre levy, NAD 3 per incandescent light bulb, a NAD 0.50 plastic bag levy, NAD 1.80 per litre on lubricants and oils, and a 5% levy on primary and disposable batteries.
Double taxation agreements (DTAs)
Namibia has active DTAs with South Africa, Botswana, Mauritius, Malaysia, India, Russia, Germany, France, Sweden, Romania, and the UK; the Canada DTA remains unratified. The treaties generally follow the OECD model and limit taxation of non-residents to Namibian-source profits attributable to a permanent establishment (PE). NamRA is also developing a national DTA policy framework to guide future treaty negotiations.
Special incentives & anti-avoidance framework
- EPZ phase-out to SEZ: The legacy Export Processing Zone (EPZ) regime is phased out, with qualifying export businesses transitioning to Special Economic Zones (SEZs) offering a reduced corporate tax rate of 20%.
- Transfer pricing: Non-arm’s length transactions between related entities are subject to adjustment by NamRA under Practice Note 2 of 2006 (based on OECD guidelines). Penalties up to 200% and interest of 20% p.a. apply to underpaid tax.
- Thin capitalisation: Interest deductions on connected-party debt are limited to 30% of tax EBITDA where net interest exceeds NAD 3 million.
- Loss carry-forward caps: Tax loss carry-forwards are capped at NAD 1,000,000 or 80% of taxable income per year, with a maximum time limit of 10 years for mining, petroleum, and green hydrogen, and 5 years for all other sectors.
Taxation of individuals
Residents and non-residents are taxed on Namibian-source income under the same progressive scale, with 7 tax brackets and a maximum rate of 37% on income above NAD 1,550,001.
Income up to NAD 100,000 is tax-free. Individual interest income is subject to a 10% final withholding tax, except for Nampost Savings Bank interest.
Annual deductions for qualifying pension, provident, retirement annuity, and educational policy contributions are capped at NAD 150,000.
