DT4055 - Double Taxation Relief Manual: Guidance by country: Brunei: Notes

Residence (paragraph 2)

A person is a resident of the UK if they are resident in the UK under UK domestic law and not resident of Brunei under Brunei’s domestic law.

A company is resident in the UK if it is managed and controlled in the UK and resident in Brunei is if it managed and controlled in Brunei. The residence tie-breaker for corporate entities is determined according to management and control.