SolvedDT4055 | Double Taxation Relief Manual: Brunei: Notes
From HM Revenue & Customs · Double Taxation Relief Manual
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.