Immovable property taxation permits source state taxation of property income and applies to use, letting, enterprises, and services. Income from immovable property situated in the source State may be taxed there when derived by a resident of the other Contracting State; this includes agriculture and forestry receipts and income from direct use, letting or other forms of utilisation. 'Immovable property' is defined by the law of the State where the property lies and includes accessories, livestock, agricultural equipment, rights subject to landed property law, usufruct and payments for working mineral deposits and other natural resources, but excludes ships and aircraft. The rule also applies to enterprise property income 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.
Immovable property taxation permits source state taxation of property income and applies to use, letting, enterprises, and services.
Income from immovable property situated in the source State may be taxed there when derived by a resident of the other Contracting State; this includes agriculture and forestry receipts and income from direct use, letting or other forms of utilisation. "Immovable property" is defined by the law of the State where the property lies and includes accessories, livestock, agricultural equipment, rights subject to landed property law, usufruct and payments for working mineral deposits and other natural resources, but excludes ships and aircraft. The rule also applies to enterprise property income and to property used for independent personal services.
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