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HMRC internal manual

Double Taxation Relief Manual

HM Revenue & Customs
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Brunei: Dividends

No Brunei tax is at present deducted from dividends paid by a Brunei company. If at any time Brunei imposes a withholding tax on dividends, a United Kingdom resident recipient would be exempt from such tax if he was subject to tax in the United Kingdom on such dividends (Article 6(4) as introduced by Article 1 of the 1973 amending agreement).

A United Kingdom company which controls, directly or indirectly, at least 10 per cent of the voting power in a Brunei company paying a dividend is entitled to credit for the underlying tax (see INTM164010(d)) (Article 12(1)(b) as introduced by Article 1 of the 1968 amending agreement).