Taxation of immovable property income permits taxation in the State where the property is situated, including accessory rights. Income derived by a resident of one Contracting State from immovable property situated in the other Contracting State may be taxed in the State where the property is located. Immovable property is defined by local law and includes accessory property, agricultural and forestry equipment and livestock, certain rights and usufruct, and payments for working natural resources; ships, boats and aircraft are excluded. The rule covers income from direct use, letting or other uses and applies to enterprise income and income from 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 permits taxation in the State where the property is situated, including accessory rights.
Income derived by a resident of one Contracting State from immovable property situated in the other Contracting State may be taxed in the State where the property is located. Immovable property is defined by local law and includes accessory property, agricultural and forestry equipment and livestock, certain rights and usufruct, and payments for working natural resources; ships, boats and aircraft are excluded. The rule covers income from direct use, letting or other uses and applies to enterprise income and income from independent personal services.
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