Income from immovable property may be taxed in the source state under the DTAA, including usufruct and resource rights. Income derived 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 defined by the law of the State where the property is situated and includes accessories, livestock and agricultural equipment, usufructs, and rights to payments for working mineral deposits, while excluding ships, boats, aircraft and motor vehicles. The provision covers income from direct use, letting or other use and applies to enterprise 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 source state under the DTAA, including usufruct and resource rights.
Income derived 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 defined by the law of the State where the property is situated and includes accessories, livestock and agricultural equipment, usufructs, and rights to payments for working mineral deposits, while excluding ships, boats, aircraft and motor vehicles. The provision covers income from direct use, letting or other use and applies to enterprise income and property used for independent personal services.
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