Taxation of immovable property income: source State may tax income from property situated within its territory. 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 lies and includes accessories, agricultural livestock and equipment, usufructs, and payments for working mineral deposits; ships and aircraft are excluded. The rule covers income from direct use, letting or other use and applies to enterprises and 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.
Taxation of immovable property income: source State may tax income from property situated within its territory.
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 lies and includes accessories, agricultural livestock and equipment, usufructs, and payments for working mineral deposits; ships and aircraft are excluded. The rule covers income from direct use, letting or other use and applies to enterprises and independent personal services.
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