Income from immovable property may be taxed in the state where the property is situated under the treaty. Income derived by a resident of one Contracting State from immovable property situated in the other Contracting State may be taxed in the State where the property is located. Immovable property is defined by local law and includes accessories, livestock and equipment used in agriculture and forestry, usufruct, and rights to payments for working mineral deposits and other natural resources; ships, boats and aircraft are excluded. The rule covers income from direct use, letting or other forms of use, and applies to enterprise income and income from independent personal services.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Income from immovable property may be taxed in the state where the property is situated under the treaty.
Income derived by a resident of one Contracting State from immovable property situated in the other Contracting State may be taxed in the State where the property is located. Immovable property is defined by local law and includes accessories, livestock and equipment used in agriculture and forestry, usufruct, and rights to payments for working mineral deposits and other natural resources; ships, boats and aircraft are excluded. The rule covers income from direct use, letting or other forms of use, and applies to enterprise income and income from independent personal services.
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