Taxation of immovable property: income from property is taxable in the State where the property is situated under the treaty. Income from immovable property located in a Contracting State may be taxed by that State; immovable property is defined by local law and includes accessories, agricultural livestock and equipment, usufruct, and payments for working mineral deposits, while excluding ships, boats and aircraft. The rule covers income from direct use, letting or other use, and applies equally to enterprise income from property and income from property used to perform 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.
Taxation of immovable property: income from property is taxable in the State where the property is situated under the treaty.
Income from immovable property located in a Contracting State may be taxed by that State; immovable property is defined by local law and includes accessories, agricultural livestock and equipment, usufruct, and payments for working mineral deposits, while excluding ships, boats and aircraft. The rule covers income from direct use, letting or other use, and applies equally to enterprise income from property and income from property used to perform independent personal services.
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