Income from immovable property: source-state taxing rights apply to use, letting and resource related payments. Income of a resident from immovable property situated in the other Contracting State may be taxed in the State where the property is located; this covers income from direct use, letting or other use. 'Immovable property' is determined by local law and includes accessories, agricultural livestock and equipment, land-related legal rights, usufruct and payments for working mineral deposits and other natural resources, while excluding ships, boats and aircraft. The rule also applies to enterprise income from property and to 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: source-state taxing rights apply to use, letting and resource related payments.
Income of a resident from immovable property situated in the other Contracting State may be taxed in the State where the property is located; this covers income from direct use, letting or other use. "Immovable property" is determined by local law and includes accessories, agricultural livestock and equipment, land-related legal rights, usufruct and payments for working mineral deposits and other natural resources, while excluding ships, boats and aircraft. The rule also applies to enterprise income from property and to property used for independent personal services.
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