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DT4078 | DT: Brunei: double taxation agreement, Article 9 Income from personal (including professional) services

From HM Revenue & Customs · Double Taxation Relief Manual

9.-

  1. An individual who is a resident of the United Kingdom shall be exempt from Brunei tax on profits or remuneration in respect of personal (including professional) services performed within Brunei in any year of assessment if-

  1. he is present within Brunei for a period or periods not exceeding in the aggregate 183 days during that year, and

  2. the services are performed for or on behalf of a person resident in the United Kingdom, and

  3. the profits or remuneration are subject to United Kingdom tax.

  1. An individual who is a resident of Brunei shall be exempt from United Kingdom tax on profits or remuneration in respect of personal (including professional) services performed within the United Kingdom in any year of assessment if-

  1. he is present within the United Kingdom for a period or periods not exceeding in the aggregate 183 days during that year, and

  2. the services are performed for or on behalf of a person resident in Brunei, and

  3. the profits or remuneration are subject to Brunei tax.

  1. The provisions of this paragraph shall not apply to the profits or remuneration of public entertainers such as stage, motion picture or radio artistes, musicians and athletes.