Income from immovable property: taxable only in the State where the property is situated, covering use and letting. Income from immovable property is taxable only in the Contracting State where the property is situated, covering income from direct use, letting, or other exploitation. The term immovable property is defined by the law and usage of that State and includes accessories, agricultural livestock and equipment, lights governed by landed property law, usufructs, and rights to payments for working mineral deposits and other natural resources; ships and aircraft are excluded. The situs taxation rule also applies to enterprise income and income 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: taxable only in the State where the property is situated, covering use and letting.
Income from immovable property is taxable only in the Contracting State where the property is situated, covering income from direct use, letting, or other exploitation. The term immovable property is defined by the law and usage of that State and includes accessories, agricultural livestock and equipment, lights governed by landed property law, usufructs, and rights to payments for working mineral deposits and other natural resources; ships and aircraft are excluded. The situs taxation rule also applies to enterprise income and income used for independent personal services.
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