Immovable property taxation: source State may tax income from land, including agricultural and mineral rights.

Taxing power for income from immovable property is allocated to the State where the property is situated: a resident of one Contracting State who derives income from immovable property located in the other Contracting State may be taxed in that other State. Immovable property is defined by the law of the State where the property lies and includes accessories to land, agriculture and forestry assets, rights governed by landed property law, usufruct, and payments for working mineral deposits; ships, boats, aircraft and motor vehicles are excluded. Income from direct use, letting, other uses, enterprise holdings and property used for independent personal services fall within the Article.

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