Income from immovable property: source state may tax property income and related business or professional uses. Income from immovable property is taxable in the Contracting State where the property is situated; 'immovable property' is defined by the law of that State and includes accessories, agricultural livestock and equipment, landed-property rights, usufruct, and payment rights for working mineral deposits and natural resources, while excluding ships and aircraft. The State-of-location taxing right applies to income from direct use, letting or other use, and extends to enterprise income and property used to perform professional 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 income and related business or professional uses.
Income from immovable property is taxable in the Contracting State where the property is situated; "immovable property" is defined by the law of that State and includes accessories, agricultural livestock and equipment, landed-property rights, usufruct, and payment rights for working mineral deposits and natural resources, while excluding ships and aircraft. The State-of-location taxing right applies to income from direct use, letting or other use, and extends to enterprise income and property used to perform professional services.
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