Income from immovable property may be taxed where the property is located, covering use, letting and related rights. 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. ''Immovable property'' is defined by the law of the State where the property lies and includes accessory property, landed property rights, usufruct and rights to payments for working or the right to work natural resources; ships, boats and aircraft are excluded. The rule covers income from direct use, letting or other use and 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 may be taxed where the property is located, covering use, letting and related rights.
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. ''Immovable property'' is defined by the law of the State where the property lies and includes accessory property, landed property rights, usufruct and rights to payments for working or the right to work natural resources; ships, boats and aircraft are excluded. The rule covers income from direct use, letting or other use and applies to enterprise property income and property used for independent personal services.
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