Registering for Non-Resident Shareholders’ Tax (NRST) with NamRA

Registering for Non-Resident Shareholders’ Tax (NRST) with NamRA

Learn how to register for Non-Resident Shareholders Tax (NRST) with NamRA in Namibia, including the NRST rate, ITAS registration, withholding tax, dividends, application form, tax returns, tax payment and compliance requirements.

When a Namibian company declares dividends to a shareholder who is not resident in Namibia, the payment may be subject to non-resident shareholders tax (NRST). NRST is a form of withholding tax applied to dividends paid or declared to non-resident shareholders.

The Namibian company responsible for declaring the dividend generally has the obligation to withhold the tax and account for it to the Namibia Revenue Agency (NamRA). NamRA’s official guidance confirms that NRST applies to dividends declared by a company to a shareholder who is not a Namibian resident.

For businesses with foreign ownership, understanding NamRA registration, the applicable NRST rate, the correct application form, and ongoing filing requirements is essential for maintaining proper tax compliance.

This guide explains what NRST is, who needs to register, how to register through the ITAS system, how the tax is calculated, and what companies must do after registration.

What Is Non-Resident Shareholders Tax in Namibia?

Non-Resident Shareholders Tax (NRST) is a withholding tax on dividends declared by a Namibian company to a shareholder who is not resident in Namibia.

NRST is different from ordinary income tax. Income tax generally concerns taxable income earned by a taxpayer, while NRST is a withholding obligation that arises when qualifying dividends are declared to non-resident shareholders.

NamRA includes NRST among its withholding tax categories. Its tax guidance explains that NRST is payable on dividends declared by a company to a shareholder who is not a Namibian resident.

A company making payments to foreign shareholders should therefore determine the nature of each payment before processing it. A dividend, interest payment, royalty, consultancy fee, and other payment may have different tax consequences.

Who Needs to Register for NRST?

NRST registration is relevant to a Namibian business that has an obligation to withhold tax from dividends declared to non-resident shareholders.

For example, a foreign-owned company incorporated in Namibia may have shareholders living outside Namibia. If that company declares dividends to those shareholders, the company should consider whether NRST applies and register for the relevant tax obligation.

The key considerations include:

  • Whether the payer is a Namibian company.
  • Whether the payment is a dividend.
  • Whether the shareholder is a non-resident shareholder.
  • The shareholder’s ownership percentage.
  • The identity and status of the beneficial owner.
  • Whether a double taxation agreement may affect the applicable rate.
  • Whether the company is already registered for other relevant tax types.

NRST registration should not be confused with general tax registration. A business may have several separate tax obligations depending on its activities and transactions.

NamRA’s ITAS system provides resources for taxpayers handling registration and electronic filing. You can access the ITAS for Namibia portal to review available registration and e-filing resources.

What Is the NRST Rate in Namibia?

The NRST rate generally depends on the ownership structure and the status of the shareholder.

NamRA’s current tax information states that the rate is 10% where the beneficial shareholding company holds at least 25% of the capital of the Namibian company, and 20% in other cases.

PwC’s Namibia tax summary, reviewed on 16 July 2026, reports the same general distinction and notes that double taxation agreement relief may apply in qualifying circumstances.

Dividend recipient situationGeneral NRST rate
Non-resident company holding at least 25% of the Namibian company’s shares/capital10%
Other cases20%

The ownership requirement should be examined carefully before a company applies the lower rate. A business should also check whether a relevant tax treaty changes the rate.

For current tax information, the NamRA income tax and tax information provides an additional reference point for the applicable NRST rules.

Example of NRST Calculation

Suppose a Namibian company declares N$500,000 in dividends to a qualifying non-resident corporate shareholder that meets the applicable 25% ownership threshold.

At a 10% NRST rate:

N$500,000 × 10% = N$50,000

The company would withhold N$50,000 and pay the remaining N$450,000 to the shareholder, assuming no other adjustment or treaty treatment applies.

If the 20% rate applies:

N$500,000 × 20% = N$100,000

The shareholder would receive N$400,000 after the withholding.

These examples are illustrations only. The correct withholding tax rate should be determined from the company’s ownership structure, the shareholder’s status, and any applicable tax agreement.

How to Register for NRST with NamRA

The NRST registration process involves obtaining the appropriate registration documentation and submitting it through the applicable NamRA process.

1. Access the NamRA ITAS Portal

The first step is to access the NamRA electronic tax administration system.

The ITAS platform provides taxpayers with access to registration documents, tax administration services and electronic filing resources.

Businesses should make sure that their existing taxpayer information is accurate before adding another tax obligation to their profile. Businesses can also review guidance on registering a business in Namibia when establishing the underlying business structure.

2. Find the NRST Application Form

NamRA provides an Application for Registration – Non Resident Shareholder’s Tax.

The relevant NamRA application forms include the NRST registration form as well as forms for other tax obligations, such as withholding tax on services and tax on royalties.

Using the correct application form is important because NRST is a distinct tax obligation. Companies should also review the forms and fees for registering a private company where the Namibian company is being established as a private company.

3. Prepare the Company Information

The company should provide accurate information corresponding with its existing NamRA records.

Depending on the registration requirements and the company’s circumstances, information may include:

  • Registered company name
  • Taxpayer identification information
  • Company registration information
  • Contact details
  • Business activities
  • Shareholder information
  • Dividend information
  • Beneficial ownership information
  • Relevant banking or representative information

The information submitted should be consistent with the company’s corporate and tax records.

Where the company is newly established, it should ensure that its underlying corporate and tax records are properly organised before commencing dividend distributions. Companies can review the requirements for registering a company in Namibia to understand the broader corporate documentation involved.

4. Provide Non-Resident Shareholder Details

The company should accurately identify the non-resident shareholder receiving the dividends.

Important information may include:

  • Shareholder’s legal name
  • Country of residence
  • Whether the shareholder is an individual or company
  • Percentage of shares held
  • Nature of the ownership
  • Beneficial ownership
  • Amount of dividends declared
  • Date the dividends were declared

The concept of beneficial shareholding is particularly important where the legal shareholder and ultimate economic owner are not the same person or entity.

Companies with layered international ownership should carefully review their shareholder records before applying an NRST rate.

5. Confirm the Underlying Company Structure

The company’s legal structure can affect the documentation and corporate records available for tax administration. A company operating as a private limited company can review private limited company registration in Namibia for information about that structure.

Other legal structures may have different registration requirements, including close corporation registration in Namibia, Section 21 company registration, or NGO registration in Namibia.

What Documents May Be Needed for NRST Registration?

The exact documentation required can depend on the taxpayer’s circumstances and NamRA’s registration process.

Companies should have their corporate records, tax registration details and shareholder information available. It is also sensible to retain documents supporting the ownership percentage used when determining the applicable NRST rate.

A company should keep copies of:

  • Certificate of incorporation or company registration documents
  • Taxpayer registration information
  • Share register
  • Shareholder identification or corporate documents
  • Beneficial ownership information
  • Dividend resolutions
  • Dividend calculations
  • NRST registration documentation
  • Evidence supporting a treaty position, where applicable

The goal is to ensure that the company can demonstrate how it determined the amount of tax withheld.

Companies that need to demonstrate their tax standing can also review the process for obtaining a NamRA certificate of good standing.

Submit the NRST Registration Application

Once the required information has been prepared, the company can submit its NRST registration through the applicable NamRA process.

The ITAS application forms page specifically lists an Application for Registration – Non Resident Shareholder’s Tax.

If the company’s ownership structure is complicated or the correct tax treatment is uncertain, it is advisable to clarify the requirements before submitting incomplete or inconsistent information. For assistance with tax administration matters, businesses can contact a Namibia business services provider to discuss the relevant requirements.

The same principle applies where the company has multiple foreign shareholders, nominee arrangements, holding companies or shareholders resident in different countries.

NRST for Foreign-Owned Namibian Companies

NRST is particularly relevant to many foreign-owned companies operating in Namibia.

A company incorporated in Namibia can have shareholders who live outside the country. The fact that the business has foreign ownership does not mean that every payment made to a shareholder is automatically a dividend or subject to the same withholding tax.

A foreign shareholder may receive:

  • Dividends
  • Interest
  • Consultancy fees
  • Management fees
  • Royalties
  • Directors’ fees
  • Other payments

Each payment must be classified according to the applicable tax rules.

Businesses considering foreign investment can also review this guide on registering a company in Namibia as a foreigner, which discusses the broader company establishment process.

Companies with owners who want to operate from outside Namibia can also consider remote business setup in Namibia when planning their operating structure.

NRST and Double Taxation Agreements

Namibia has entered into double taxation agreements with certain countries. Depending on the circumstances, a treaty may provide a reduced withholding rate.

PwC’s current Namibia withholding-tax guidance identifies treaty-specific rates for several countries and notes that DTA relief may be available for NRST.

A company should not automatically apply a treaty rate simply because its shareholder is resident in a country that has a tax agreement with Namibia.

Before applying treaty relief, the company should consider:

  1. The shareholder’s tax residence.
  2. The relevant treaty.
  3. The ownership percentage.
  4. The definition of dividends under the treaty.
  5. Beneficial ownership requirements.
  6. Any documentation required to support the reduced rate.

Where there is uncertainty, professional tax advice may be appropriate.

NRST Payment and Tax Return Deadline

Registering for NRST is only the beginning of the company’s compliance obligations.

When dividends are subsequently declared to a non-resident shareholder, the company must calculate the appropriate tax, withhold the amount and submit the required tax returns and tax payment to NamRA within the applicable deadline.

NamRA’s guidance states that payment and submission of the relevant return are due within 20 days after the end of the month during which the amount was withheld.

PwC’s 2026 Namibia tax administration summary likewise states that withholding tax on dividends is due within 20 days after declaration of the dividend.

Companies should therefore maintain an internal process that records:

  • Date of dividend declaration
  • Gross dividend
  • Applicable NRST rate
  • Amount withheld
  • Net dividend paid
  • NRST return
  • Tax payment
  • Proof of submission
  • Supporting corporate resolutions

Businesses should also ensure their taxpayer banking information remains accurate. Guidance on updating taxpayer bank details on the NamRA portal can help with this administrative requirement, while information on linking a bank account to a NamRA tax profile covers another related taxpayer administration process.

NRST Compared With Other Withholding Taxes

NRST is only one category of withholding tax that can affect transactions involving non-residents.

Namibia also applies withholding tax to certain interest, royalty and service payments. This means a company should identify the nature of a transaction before determining the appropriate tax.

NamRA’s withholding tax guidance provides information on NRST and other withholding tax categories.

Withholding Tax on Services

Certain management and consultancy payments made by Namibian residents to non-residents can attract withholding tax.

PwC’s current Namibia guidance states that management and consultancy fees paid to non-residents are generally subject to a 10% withholding tax, subject to applicable treaty rules.

Businesses can also review how to register for non-resident withholding tax on services when dealing with qualifying service payments.

NamRA also provides a separate withholding tax on services form for relevant transactions.

Withholding Tax on Royalties

Withholding tax on royalties is another separate obligation.

Royalty payments to non-residents can include payments associated with intellectual property and certain rights. PwC’s current Namibia guidance states that withholding tax on royalties is generally 10%, subject to applicable treaty treatment.

Companies can review this guide to withholding tax on royalties in Namibia when assessing royalty-related obligations.

A company should therefore avoid automatically classifying every payment to a foreign shareholder as a dividend.

Withholding Tax on Interest

Interest paid to non-residents can also attract withholding tax. PwC’s current Namibia tax guidance identifies a general 10% withholding tax on interest paid to non-residents, subject to the applicable rules and potential treaty relief.

This distinction is important where a shareholder provides a loan to the company. The resulting interest payment is not the same as a dividend and may have a different withholding treatment.

NRST and Income Tax Compliance

NRST does not replace the company’s ordinary income tax responsibilities.

A Namibian company may need to deal with several tax obligations depending on its activities, including corporate income tax, VAT, employee-related taxes and withholding taxes.

The company should therefore maintain a complete tax compliance calendar covering:

  • Income tax returns
  • Provisional tax payments
  • NRST returns
  • Dividend withholding
  • Other withholding taxes
  • VAT, where applicable
  • Payroll-related obligations
  • Supporting tax records

Businesses that also need VAT registration can review how to register for VAT with NamRA.

Employers with staff should also consider their PAYE obligations and the process for registering as an employer for PAYE in Namibia.

PwC’s current Namibia tax administration guidance notes that corporate income tax returns and provisional payments have their own separate deadlines from withholding tax obligations.

Common NRST Registration Mistakes

Using the Wrong Tax Type

NRST should not be confused with ordinary income tax or another withholding tax category.

The company should select the appropriate NRST registration process and keep evidence of the registration.

Applying the Wrong NRST Rate

The 10% and 20% rates apply in different circumstances. Ownership and shareholder status must be examined before the company determines its withholding obligation.

Ignoring Beneficial Ownership

A legal shareholder may not always represent the ultimate beneficial owner. International ownership structures should therefore be reviewed carefully.

Missing the Payment Deadline

The applicable NRST payment and filing deadline should be tracked from the relevant dividend transaction. NamRA guidance specifies the 20-day deadline for the relevant withholding tax payment and return.

Treating Foreign Payments as Dividends Automatically

Not every payment made to a foreign shareholder is a dividend. Interest, royalties, consultancy fees and other payments may fall under different withholding tax provisions.

Failing to Keep Supporting Records

A company should retain sufficient documentation to explain how the dividend, shareholder status, applicable rate and tax calculation were determined.

Where another person needs to deal with NamRA on behalf of the taxpayer, businesses can review the process for assigning a special power of attorney for Namibian tax matters.

NRST Compliance Checklist

Before completing NRST registration, a company can use this checklist:

  • Confirm that the business is properly registered for tax.
  • Confirm that the payment involves a non-resident shareholder.
  • Verify the shareholder’s country of tax residence.
  • Confirm the shareholder’s percentage ownership.
  • Review the beneficial ownership structure.
  • Obtain the correct NRST application form.
  • Confirm the company’s NamRA records.
  • Determine the applicable NRST rate.
  • Check whether a double taxation agreement applies.
  • Calculate the withholding amount.
  • Record the dividend declaration date.
  • Submit the relevant NRST tax return.
  • Make the required tax payment.
  • Keep proof of submission and payment.
  • Retain shareholder and dividend documentation.

Companies should also consider their wider operational requirements, including business setup services in Namibia, company secretarial services, and a virtual office in Namibia where appropriate.

If the business imports or exports goods, its broader compliance requirements may also include an import-export licence.

For companies that use a tax agent or another representative, accurate documentation and authority should be maintained throughout the relationship.

Frequently Asked Questions About NRST in Namibia

1. What is the NRST rate in Namibia?

The general NRST rate is 10% where a qualifying non-resident company holds at least 25% of the capital of the Namibian company and 20% in other cases. Applicable double taxation agreements can provide different rates in qualifying circumstances.

2. Who is responsible for paying NRST?

The Namibian company declaring the dividend is generally responsible for withholding the NRST and paying it to the tax authority.

3. When must NRST be paid to NamRA?

The relevant NRST payment and return are generally due within 20 days after the end of the month in which the amount was withheld.

For businesses that need to address other tax administration matters, related guidance is available on claiming a tax refund from NamRA and registering a trust for tax purposes with NamRA.

Foreign investors can also review the requirements to register a company in Namibia as a foreigner when establishing a Namibian company and assessing its subsequent tax obligations.

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