xmlns:atom="http://www.w3.org/2005/Atom"
Where, under any provision of this Convention, a partnership or joint venture is entitled, as a resident of Ukraine, 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 or joint venture 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 Ukraine.