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Income from immovable property may be taxed in the source state; definition and scope clarified under the treaty. Income from immovable property of a resident derived from immovable property situated in the other Contracting State may be taxed in the State where the property is situated. The treaty uses the domestic law definition of immovable property and expressly includes accessories, agricultural and forestry livestock and equipment, landed-property rights, usufruct and rights to payments for working mineral deposits and other natural resources, excludes ships, boats and aircraft, and extends the source-state taxing right to income from direct use, letting, enterprise property income, and property used for independent personal services.
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Provisions expressly mentioned in the judgment/order text.
Income from immovable property may be taxed in the source state; definition and scope clarified under the treaty.
Income from immovable property of a resident derived from immovable property situated in the other Contracting State may be taxed in the State where the property is situated. The treaty uses the domestic law definition of immovable property and expressly includes accessories, agricultural and forestry livestock and equipment, landed-property rights, usufruct and rights to payments for working mineral deposits and other natural resources, excludes ships, boats and aircraft, and extends the source-state taxing right to income from direct use, letting, enterprise property income, and property used for independent personal services.
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