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5.5. Source Rules with Respect to Income Derived by Non-Residents

Income earned by non-residents from sources in Brunei without a PE is subject to tax in the country. Income is considered as derived from Brunei if it is:

  • derived from any business activity, including of ship owner or charterer, business of air-transport or business of telecommunication;
  • derived from any loans or funds or services relating to any loans or funds, provided to a resident of Brunei or funds are brought into and used in Brunei;
  • derived from the disposal of a shareholder’s interest in a resident company; or
  • derived from the rental of movable property used in Brunei; or
  • derived from the use of, right to use or services rendered in connection with scientific, industrial, technical or commercial knowledge etc.