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HMRC internal manual

Double Taxation Relief Manual

DT:Kazakhstan: double taxation agreement, Article 24: Partnerships


Where, under any provision of this Convention, a partnership, joint venture or other entity is entitled, as a resident of Kazakhstan, 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, joint venture or other entity 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 Kazakhstan.