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Immovable property taxation: income from property may be taxed in the jurisdiction where the property is located under treaty. Income derived by a resident 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 property State and includes accessories, agricultural livestock and equipment, rights governed by landed property law, usufruct and payments for working mineral deposits and other natural resources; ships, boats and aircraft are excluded. The taxing rule covers income from direct use, letting or other forms of use and extends to enterprise income and income 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.
Immovable property taxation: income from property may be taxed in the jurisdiction where the property is located under treaty.
Income derived by a resident 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 property State and includes accessories, agricultural livestock and equipment, rights governed by landed property law, usufruct and payments for working mineral deposits and other natural resources; ships, boats and aircraft are excluded. The taxing rule covers income from direct use, letting or other forms of use and extends to enterprise income and income used for independent personal services.
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