Article 4 addresses partnership agreements concluded outside Oman that do not possess a separate legal personality in their home jurisdiction. For Oman tax purposes, such agreements are treated as forming a separate, independent legal person regardless of the partners' liability limits for debts. This classification ensures that any income accruing to a permanent establishment in Oman owned by this deemed legal person is subject to tax. This provision prevents tax avoidance by foreign partnerships and ensures consistency in the taxation of business activities conducted through collaborative, non-incorporated structures within the Sultanate.