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

Income from immovable property under the DTAA may be taxed in the Contracting State where the property is situated; this applies to income from direct use, letting or other forms of use. Immovable property is defined by the law of the State where the property is located and includes accessories to land, livestock and equipment used in agriculture and forestry, rights governed by landed-property law, usufruct, and payments for working mineral deposits and other natural resources; ships, boats and aircraft are excluded. The rule also covers enterprise income from such property and property used for independent personal services.

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