Section 47
Double taxation arrangements with other territories
of I Ncome Tax (Petroleum) Act
(1)
If the Minister, with the approval of His Majesty the Sultan and
Yang Di-Pertuan, by order declares that arrangements specified in the order have been made with the Government of any country or territory outside
Brunei Darussalam with a view to affording relief from double taxation in relation to tax imposed under the provisions of this Act and any tax of a similar character imposed by the laws of that country or territory, and that it is expedient that those arrangements should have effect, the arrangements shall have effect notwithstanding anything in any Act to the contrary.
(2)
(Repealed).
(3)
The Minister may make rules for carrying out the provisions of any arrangements having effect under this section.
(4)
An order made under the provisions of subsection (1) may include provisions for relief from tax for years of assessment commencing or terminating before the making of the order and provisions as to income
(which expression includes profits) which is not itself liable to double taxation.
(5)
Where, before the publication of this Act in the Gazette upon enactment, any order has been made under the provisions of section 41 of the
Income Tax Act (Chapter 35) and the arrangements specified in that order, with any modifications, are expressed to apply to a tax in any country or territory outside Brunei Darussalam and to income tax in Brunei Darussalam and to any other taxes of a substantially similar character either imposed in that country or territory or Brunei Darussalam or imposed by either
Contracting Party to any such arrangements after those arrangements came into force and —
(a)
such order was made before 1st January 1963, then for the purposes of this Act that order is deemed to have been made under this section on that day and those arrangements shall have effect, in
Brunei Darussalam, as respects tax for any year of assessment; or
Income Tax (Petroleum)
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(b)
such order was made after 31st December 1962, then, for the purposes of this Act, that order is deemed to have been made under this section on that day and those arrangements specified therein shall have effect, in Brunei Darussalam, as respects tax for any year of assessment beginning on or after the date when those arrangements come into force and for the unexpired portion of any year of assessment current at that date.