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The Double Taxation Relief (Taxes on Income) (Malta) Order 1995
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ARTICLE 24Partnerships
(1) Where, under any provision of this Convention, a partnership is entitled, as a resident of Malta, to exemption from tax in the United Kingdom on any income or capital gains, that provision shall not be construed as restricting the right of the United Kingdom to tax any partner who is a resident of the United Kingdom on his share of such income or capital gains; but any such income or gains shall be treated for the purposes of Article 22 of this Convention as income or gains from sources in Malta.
(2) Nothing in Article 10 of this Convention shall entitle a partnership which is a resident of Malta to a tax credit in respect of dividends paid to the partnership by a company which is a resident of the United Kingdom; but any partner who is a resident of Malta shall be treated for the purposes of the said Article 10 and of this paragraph as having been paid a dividend of an amount corresponding to his share of those dividends by the company which is a resident of the United Kingdom.
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