Immovable property taxation: income taxed in the state where the property is situated, including resource and usufruct rights.

Income from immovable property may be taxed in the Contracting State where the property is situated. "Immovable property" is defined by the law of that State and includes accessories, livestock and agricultural equipment, rights governed by landed property law, usufruct, and payments for working mineral deposits and other natural resources, while excluding ships, boats and aircraft. The source-taxation rule covers 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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