This paper applies a new institutional framework to analyse the generation and distribution of tourism income in Namibian communal lands. Utilising two of Williamson's four levels of institutions, it is shown that reallocating and securing property rights (rules of the game), is essential to allow rural communities to benefit from tourism activities on their land. Contingent to those rights and local communities' capacity and social capital, a typology of institutional arrangements (play of the game), is proposed that govern relationships between actors (local communities, the private sector and the State), in the tourism sector. Overall, this framework facilitates understanding of why and how actors craft specific governance structures in order to operate tourism activities, redistribute revenues and minimise transaction costs.