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HMRC internal manual

Double Taxation Relief Manual

Brunei: Treaty Summary

Brunei Double Taxation Arrangement

Page 3: Treaty summary

The table summarises the provisions of the treaty as they relate to income beneficially owned by UK residents. The rate shown is the ‘treaty rate’ and does not reflect taxes chargeable under domestic law before relief is given under the provisions of the treaty. The ‘treaty rate’ is the maximum rate at which Brunei is permitted to tax income in the relevant categories under the treaty. Rates chargeable under domestic law may be higher or lower.

In all cases other conditions for relief (e.g. beneficial ownership) will have to be met before relief is due under the treaty. The text of the treaty itself should be consulted for the full details. The text of the treaty can be found on

Portfolio dividends 0% (Note 1) Para. 6
Dividends on direct investments 0% (Note 1) Para. 6
Conditions for lower rate on dividends on direct investments n/a  
Property income dividends 0% (Note 1) Para. 6
Interest No relief n/a
Royalties 0% (Note 1) Para. 7
Government pensions Taxable only in Brunei unless individual is ordinarily resident in the UK Para. 8
Other pensions Exempt from tax in Brunei (includes annuities) Para. 10
Arbitration No n/a


Note 1: The income must be subject to tax for limitations on taxation provided by the arrangement to apply.