Namibia published the Income Tax Amendment Act, 2022 (Act No. 13 of 2022) on 29 December 2022. One of the key measures is the introduction of a formal thin capitalization rule in Section 95A of the Income Tax Act (ITA) with a three-to-one (3:1) debt-equity ratio.

The rule provides that where a resident company receives financial assistance from any non-resident company or person that has an …