Income from immovable property may be taxed in the State where the property is situated under DTAA rules. 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; this includes income from agriculture or forestry, direct use, letting or other exploitation. The term immovable property is defined by the law of the State where the property is situated and includes accessories, agricultural livestock and equipment, rights subject to landed-property law, usufruct, and payments for working mineral deposits and other natural resources; ships, boats and aircraft are excluded. The rule also covers enterprise property 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.
Income from immovable property may be taxed in the State where the property is situated under DTAA rules.
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; this includes income from agriculture or forestry, direct use, letting or other exploitation. The term immovable property is defined by the law of the State where the property is situated and includes accessories, agricultural livestock and equipment, rights subject to landed-property law, usufruct, and payments for working mineral deposits and other natural resources; ships, boats and aircraft are excluded. The rule also covers enterprise property income and income used for independent personal services.
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