Where, under any provision of this Convention, a partnership is entitled, as a resident of Estonia, 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 capital gains shall be treated for the purposes of Article 23 of this Convention as income or gains from sources in Estonia.