Brunei Darussalam

Corporate - Corporate residence

Last reviewed - 09 June 2025

A company is a resident in Brunei if the control and management of the business is exercised in the country.

Non-resident means a person not known to be a resident in Brunei.

Permanent establishment (PE)

Permanent establishment means a fixed place where a business is wholly or partly carried on, including:

  • a place of management
  • a branch
  • an office
  • a factory
  • a warehouse
  • a workshop
  • a farm or plantation
  • a mine, oil well, quarry, or other place of extraction of natural resources, and
  • a building or work site or a construction, installation, or assembly project.

Without prejudice to the generality of the foregoing, a person shall be deemed to have a PE in Brunei if that person:

  • carries on supervisory activities in connection with a building or work site or a construction, installation, or assembly project, or
  • has another person acting on that person’s behalf in Brunei who:
    • has and habitually exercises an authority to conclude contracts
    • maintains a stock of goods or merchandise for the purpose of delivery on behalf of that person, or
    • habitually secures orders wholly or almost wholly for that person or for such other enterprises as are controlled by that person.