Income from immovable property may be taxed in the state where the property is situated under the treaty. Income by a resident of one Contracting State from immovable property situated in the other Contracting State may be taxed in that other State. 'Immovable property' is determined by local law and includes accessories, agricultural livestock and equipment, landed property rights, usufructs, and rights to payments for working mineral deposits and natural resources; ships, boats and aircraft are excluded. The rule covers income from direct use, letting or other use, and applies to enterprises and to immovable 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 may be taxed in the state where the property is situated under the treaty.
Income by a resident of one Contracting State from immovable property situated in the other Contracting State may be taxed in that other State. "Immovable property" is determined by local law and includes accessories, agricultural livestock and equipment, landed property rights, usufructs, and rights to payments for working mineral deposits and natural resources; ships, boats and aircraft are excluded. The rule covers income from direct use, letting or other use, and applies to enterprises and to immovable property used for independent personal services.
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