DT4054 - Double Taxation Relief Manual: Guidance by country: Brunei: 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 gov.uk.

Subject	Comments	Article
Portfolio dividends	0% (Note 1)	6
Dividends on direct investments	0% (Note 1)	6
Conditions for lower rate on dividends on direct investments	N/A	N/A
Property income dividends	0% (Note 1)	6
Interest	The arrangement does not contain a paragraph addressing interest. Domestic rates apply.	N/A
Royalties	0% (Note 1)	7
Government pensions	Taxable only in Brunei unless individual is ordinarily resident in the UK	8
Other pensions	Exempt from tax in Brunei	10
Arbitration	No	N/A

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