§ Mr. Dobsonasked the Chancellor of the Exchequer whether the double taxation agreement between the United Kingdom and South Africa includes Namibia, if so, for how long this has been the case; and whether such an 425W Arrangement is in accordance with the 1966 United Nations resolution on South-West Africa.
§ Mr. Peter Rees[pursuant to his reply, 6 August 1980]: There are two double taxation agreements currently in force with South Africa for the avoidance of double taxation, one with respect to capital transfer tax and one with respect to taxes on income and capital gains. Neither of these agreements includes Namibia.
An income tax convention with South Africa was concluded in 1962 and extended to South-West Africa in that year, and the 1967 protocol to the convention was similarly extended. This convention and protocol are no longer in force as regards South Africa but remain in force in respect of Namibia.
The resolution to which the hon. Member refers purported to terminate the mandate exercised by South Africa and to place South-West Africa under the direct responsibility of the United Nations. The force of the resolution, however, on which the United Kingdom abstained from voting, was recommendatory only, and imposed no obligations on member States.