Income from immovable property in one State may be taxed in the State where the property is located. Income 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 situated; the term is governed by the law of the property State and includes accessories, agricultural and forestry assets, usufruct, and rights to payments for working natural resources, while excluding ships, boats and aircraft. The source state rule applies to direct use, letting or other forms of use, and extends 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 in one State may be taxed in the State where the property is located.
Income 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 situated; the term is governed by the law of the property State and includes accessories, agricultural and forestry assets, usufruct, and rights to payments for working natural resources, while excluding ships, boats and aircraft. The source state rule applies to direct use, letting or other forms of use, and extends to enterprise property income and property used for independent personal services.
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