Income from immovable property: taxable in the state where the property is located under treaty rules. Income by a resident from immovable property situated in the other Contracting State may be taxed in that other State; immovable property is defined by the law of the State where the property is situated and includes accessories, agricultural livestock and equipment, rights treated as landed property, usufruct and payments for working natural resources, while ships, boats and aircraft are excluded. The rule covers income from direct use, letting or other forms of use, and applies to enterprise property income and property used for 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: taxable in the state where the property is located under treaty rules.
Income by a resident from immovable property situated in the other Contracting State may be taxed in that other State; immovable property is defined by the law of the State where the property is situated and includes accessories, agricultural livestock and equipment, rights treated as landed property, usufruct and payments for working natural resources, while ships, boats and aircraft are excluded. The rule covers income from direct use, letting or other forms of use, and applies to enterprise property income and property used for independent personal services.
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