Immovable property income may be taxed in the State where the property is situated under treaty rules. Income derived by a resident of one Contracting State from immovable property situated in the other Contracting State may be taxed in that other State; this covers income from agriculture and forestry and applies to direct use, letting or other use. 'Immovable property' is determined by the law of the State where the property is situated and includes accessories, livestock and equipment used in agriculture and forestry, rights subject to landed property law, usufruct, and payments for working mineral deposits and other natural resources; ships and aircraft are excluded. The rule also 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.
Immovable property income may be taxed in the State where the property is situated under treaty rules.
Income derived by a resident of one Contracting State from immovable property situated in the other Contracting State may be taxed in that other State; this covers income from agriculture and forestry and applies to direct use, letting or other use. "Immovable property" is determined by the law of the State where the property is situated and includes accessories, livestock and equipment used in agriculture and forestry, rights subject to landed property law, usufruct, and payments for working mineral deposits and other natural resources; ships and aircraft are excluded. The rule also applies to enterprise property income and property used for independent personal services.
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