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HMRC internal manual

Double Taxation Relief Manual

HM Revenue & Customs
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Uzbekistan: Partnerships

Under Article 3(2) of the agreement, a partnership or joint venture which derives its status from Uzbekistan law, and is therefore treated as a taxable unit in Uzbekistan, is regarded as a `person’ for the purposes of the agreement. As such, it may be entitled to claim treaty benefits, such as relief from United Kingdom tax, in respect of certain sources of income. This has no effect, however, on the United Kingdom’s right to tax United Kingdom-resident partners in Uzbekistan partnerships which benefit from the agreement. Credit for Uzbekistan tax paid by the partnership will be available, subject to the other provisions of the agreement, to United Kingdom resident partners (Article 24).

A United Kingdom resident who is a member of a partnership which is not a resident of Uzbekistan may claim relief or exemption from Uzbekistan tax in respect of his share of the income of the partnership as if he had derived that income directly.