DT4053 - Particular agreements: Brunei: Residents

An individual who is a resident of one country and also resident in the other country is not a resident of either country for the purposes of the agreement (see INTM154020).

A company is a resident of the country in which it is taxed as a resident either because it is managed and controlled in that country or because it is incorporated there. Where a company which is incorporated in the United Kingdom, but managed and controlled in Brunei, claims to be a resident of Brunei, no claim should be admitted and the case should be referred to Revenue Policy International, Business Tax Group.