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Where, under any provision of this Agreement, a partnership is entitled, as a resident of Kuwait, 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 member of the partnership 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 24 of this Agreement as income or gains from sources in Kuwait.
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