DT4056 - Brunei: Dividends
You should check the other guidance available on GOV.UK from HMRC as Brexit updates to those pages are being prioritised before manuals.
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).