Income from immovable property: source state taxation allowed; definition and application to enterprises and personal services clarified. Income from immovable property of a resident of one Contracting State derived from property situated in the other Contracting State may be taxed in the State where the property is located. This rule covers income from direct use, letting or other use, and applies to enterprise income from immovable property and to income from immovable property used for independent personal services. The term immovable property is defined by the law of the State where the property is located and includes accessories, agricultural livestock and equipment, usufruct and rights to payments for working mineral and other natural resources; ships, boats and aircraft are excluded.
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Provisions expressly mentioned in the judgment/order text.
Income from immovable property: source state taxation allowed; definition and application to enterprises and personal services clarified.
Income from immovable property of a resident of one Contracting State derived from property situated in the other Contracting State may be taxed in the State where the property is located. This rule covers income from direct use, letting or other use, and applies to enterprise income from immovable property and to income from immovable property used for independent personal services. The term immovable property is defined by the law of the State where the property is located and includes accessories, agricultural livestock and equipment, usufruct and rights to payments for working mineral and other natural resources; ships, boats and aircraft are excluded.
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