Income from immovable property may be taxed in the state where the property is located under treaty rules. Income from immovable property of a resident 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 lies and includes accessories, agricultural livestock and equipment, usufruct, and rights to payments for working mineral deposits and other natural resources, while ships, boats and aircraft are excluded. The rule covers income from direct use, letting or other uses, ownership rights conferring enjoyment via corporate shares, enterprise property income, 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 located under treaty rules.
Income from immovable property of a resident 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 lies and includes accessories, agricultural livestock and equipment, usufruct, and rights to payments for working mineral deposits and other natural resources, while ships, boats and aircraft are excluded. The rule covers income from direct use, letting or other uses, ownership rights conferring enjoyment via corporate shares, enterprise property income, and property used for independent personal services.
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