Immovable property tax: income from property situated abroad may be taxed in the source state under treaty rules. Income from immovable property derived by a resident of one Contracting State from property situated in the other may be taxed in the State where the property is located. Immovable property is defined by the law of the State where it lies and includes accessories to land, agricultural and forestry livestock and equipment, land-law rights, usufructs, and payments for working or rights to work mineral deposits and other extraction sites, excluding ships, boats and aircraft; the rule covers direct use, letting, 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.
Immovable property tax: income from property situated abroad may be taxed in the source state under treaty rules.
Income from immovable property derived by a resident of one Contracting State from property situated in the other may be taxed in the State where the property is located. Immovable property is defined by the law of the State where it lies and includes accessories to land, agricultural and forestry livestock and equipment, land-law rights, usufructs, and payments for working or rights to work mineral deposits and other extraction sites, excluding ships, boats and aircraft; the rule covers direct use, letting, enterprise property income and property used for independent personal services.
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