Taxation of real property income: may be taxed in the jurisdiction where the property is situated under treaty rules.

Income from real property may be taxed in the Contracting State where the property is situated. The Article defines real property for Australia and India to include leases, other interests, accessory property, usufruct and rights to payments tied to working, exploration or exploitation of mineral deposits, oil or gas wells, quarries and other natural resources. Such interests are situated where the underlying land or resources are located or where exploration may occur. The situs rule applies to income from direct use, letting or other forms of use and covers enterprise property income and income from property used for independent personal services.

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