Immovable property taxation: income from property may be taxed where the property is situated, including usufruct rights. Income derived by a resident of one Contracting State from immovable property situated in the other Contracting State may be taxed in that State, covering direct use, letting or other forms of exploitation, including agriculture and forestry. 'Immovable property' is determined by the law of the State where the property is located and includes accessories, livestock, agricultural equipment, usufruct and rights to payments for working mineral deposits and other natural resources, while excluding ships, aircraft and vehicles. The rule applies to enterprises, independent personal services and to rights to enjoyment of company-held property.
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.
Immovable property taxation: income from property may be taxed where the property is situated, including usufruct rights.
Income derived by a resident of one Contracting State from immovable property situated in the other Contracting State may be taxed in that State, covering direct use, letting or other forms of exploitation, including agriculture and forestry. "Immovable property" is determined by the law of the State where the property is located and includes accessories, livestock, agricultural equipment, usufruct and rights to payments for working mineral deposits and other natural resources, while excluding ships, aircraft and vehicles. The rule applies to enterprises, independent personal services and to rights to enjoyment of company-held property.
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