Income from immovable property: source State may tax property-situated income including agriculture and enterprise property uses. Income derived by a resident of one Contracting State from immovable property situated in the other State may be taxed in the State where the property is situated; this includes income from agriculture and forestry and from direct use, letting or other use. 'Immovable property' is defined by the law of the State where the property is located and includes accessory property, livestock and equipment used in agriculture and forestry, rights subject to landed property law, usufruct, and payment rights for working mineral deposits and natural resources; ships and aircraft are excluded. The taxation rule also applies to 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: source State may tax property-situated income including agriculture and enterprise property uses.
Income derived by a resident of one Contracting State from immovable property situated in the other State may be taxed in the State where the property is situated; this includes income from agriculture and forestry and from direct use, letting or other use. "Immovable property" is defined by the law of the State where the property is located and includes accessory property, livestock and equipment used in agriculture and forestry, rights subject to landed property law, usufruct, and payment rights for working mineral deposits and natural resources; ships and aircraft are excluded. The taxation rule also applies to enterprise property income and property used for independent personal services.
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