Income from real property can be taxed in the Contracting State where the property is situated under the DTAA. Article 6 provides that income from real property may be taxed in the Contracting State where the property is situated; it defines real property under each State's domestic law to include leases, other land interests, accessory property, usufruct and rights to payments for working or exploiting mineral or other deposits and natural resources, and treats such interests as situated where the underlying land or resources are located. The Article also applies to income from direct use, letting or other use of property, including 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 real property can be taxed in the Contracting State where the property is situated under the DTAA.
Article 6 provides that income from real property may be taxed in the Contracting State where the property is situated; it defines real property under each State's domestic law to include leases, other land interests, accessory property, usufruct and rights to payments for working or exploiting mineral or other deposits and natural resources, and treats such interests as situated where the underlying land or resources are located. The Article also applies to income from direct use, letting or other use of property, including enterprise property income and property used for independent personal services.
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