Income from immovable property may be taxed in the State where the property is situated under treaty rules. 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 the law of the State where the property is situated and includes accessories, agricultural and forestry assets, usufruct, and rights to payments for working mineral deposits, while ships and aircraft are excluded. The rule covers direct use, letting, other uses, enterprise income from immovable property, and 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 treaty rules.
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 the law of the State where the property is situated and includes accessories, agricultural and forestry assets, usufruct, and rights to payments for working mineral deposits, while ships and aircraft are excluded. The rule covers direct use, letting, other uses, enterprise income from immovable property, and property used for independent personal services.
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