Income from immovable property: source state taxation applies where the property is located, including resource and usufruct rights. Income from immovable property derived by a resident of one Contracting State from property situated in the other Contracting State may be taxed in the State where the property is located. 'Immovable property' is defined by local law and includes accessories, agricultural equipment, rights related to landed property, usufructs and payments for working mineral deposits and other natural resources; ships and aircraft are excluded. The Article also covers income from direct use, letting or other exploitation 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.
Income from immovable property: source state taxation applies where the property is located, including resource and usufruct rights.
Income from immovable property derived by a resident of one Contracting State from property situated in the other Contracting State may be taxed in the State where the property is located. "Immovable property" is defined by local law and includes accessories, agricultural equipment, rights related to landed property, usufructs and payments for working mineral deposits and other natural resources; ships and aircraft are excluded. The Article also covers income from direct use, letting or other exploitation and applies to enterprises and independent personal services.
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