Brunei's headline corporate income tax (CIT) rate is 18.5 (55% for petroleum operations).
0% - Brunei has no personal income tax; this applies regardless of nationality or residency status.
0% - Brunei has no VAT, GST, or general sales tax; excise duties apply to specific goods (tobacco, alcohol, motor vehicles, petroleum products) but there is no broad-based consumption tax.
Distinctive finding, confirmed via a specialist expatriate source: Brunei has no concept of personal tax residency at all, in the sense familiar from systems like the UK or France. The Income Tax Act's provisions do not apply to the personal income of individuals - arriving in and living in Brunei creates no personal income tax obligation whatsoever, irrespective of duration of stay. Tax is assessed and collected solely on the income of companies. A company is resident in Brunei if it is managed and controlled there, confirmed via a Deloitte tax-highlights compilation. Both resident and non-resident companies (including branches) are taxed on income accruing in or derived from Brunei, or received in Brunei from abroad, confirmed directly via PwC - branches are taxed the same way as subsidiaries.
Confirmed directly via PwC Worldwide Tax Summaries: "There are no special rules for taxing the undistributed income of foreign subsidiaries." A corporation, whether Brunei-resident or not, is instead taxed on foreign income only when that income is actually received in Brunei - a remittance-basis approach for foreign income rather than CFC-style attribution of undistributed foreign profits.
No statutory thin capitalization ratio was identified in available sources this session. A related but distinct mechanism was found: foreign tax relief for tax paid on foreign-source income in a Commonwealth country offering reciprocal relief is limited to tax assessed at one-half of Brunei's own tax rate, confirmed via Deloitte - though this concerns foreign tax credit relief rather than interest deductibility specifically.
No domestic FBAR/Form 8938-equivalent requiring Brunei residents to self-report their own foreign accounts was identified - consistent with Brunei having no personal tax system in the first place (see Residency above). Institutional-level CRS/FATCA participation status was not independently confirmed this session. Separately and independently of local law, US citizens and Green Card holders with Brunei accounts remain obligated to file FinCEN Form 114 (FBAR) once aggregate foreign accounts exceed USD 10,000, and potentially Form 8938, regardless of Brunei's own tax treatment.
Brunei has concluded double taxation treaties with more than 20 countries, confirmed via a specialist expatriate source, including the United Kingdom, Singapore, China, and Japan, primarily aimed at preventing double taxation of corporate income (consistent with Brunei having no personal income tax to begin with). The Ministry of Finance and Economy (MOFE) website is the official, authoritative source for the current, complete list of signed and ratified treaties - preferred over third-party compilations, which may not reflect recently concluded or updated agreements, per the same source's own explicit methodological guidance.