Cross-border income is growing. So are tax disputes.
Get the source wrong and the same income may be taxed twice or challenged by NamRA.
R230,00 VAT incl.
Cross-border work is now normal for many Namibian businesses. Export services, consulting work, and international sales have become routine. Yet the tax question remains simple and critical. Where was the income actually earned? The answer determines whether Namibia has the right to tax it. Many practitioners assume the location of payment or the residence of the client decides the matter. Tax law looks deeper. The source of income is linked to the activity that produced it. When that activity crosses borders, confusion follows. Incorrect conclusions lead to disputes, denied deductions, and exposure to foreign tax claims. A clear understanding of how income source is determined helps practitioners advise exporters and service providers with confidence while avoiding unnecessary challenges from the tax authority.
Johan Nel
Johan Nel is a seasoned tax leader and operational strategist with over a decade of experience in financial management and tax leadership. His career was shaped at PwC Namibia, where he led key strategic initiatives aligned with corporate objectives and cultivated high-performing, quality-driven teams
By attending this event, delegates will learn:
• The real meaning of source of income in tax law
• How courts determine where income is actually earned
• Why the place of payment rarely determines the tax source
• The activities that establish the source of service income
• How export income is evaluated for tax purposes
• Common mistakes when dealing with cross-border service income
• Practical indicators used to determine the true income source
• How to structure cross-border work to avoid unnecessary tax disputes
• The legal meaning of source of income in tax law
• How courts determine where income originates
• Why the place of payment does not determine source
• Activities that establish the source of service income
• Determining the source of export income
• Cross-border services and mixed source income
• Common practitioner errors when identifying income source
• How NamRA evaluates cross-border income during audits
• Structuring international work to reduce tax disputes
• Practical checks before classifying foreign income
The following event is awarded 2 CPD units in Taxation.
+27 (0) 12 643 1800/2/4 ciba@myciba.org www.myciba.org
Gauteng: Spaces, Byls Bridge Office Park, Building 14 Block B, Cnr of Olievenhoutbosch Road and Jean Avenue, Centurion, 0157
Cape Town: Cape Town Spaces Office, Century City, No1 Bridgeway Road, Bridgeways Precinct, Cape Town, 7441
Namibia: Regus Office Windhoek, Maerua Mall 3rd Floor, Windhoek, Namibia, 10005
Paris: I13 Rue Paul Valéry, 75116 Paris, France (ICFOA)
