Income from immovable property may be taxed in the State where the property is situated, including enjoyment through ownership rights. Income derived by a resident from immovable property situated in the other Contracting State 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, agricultural assets, usufruct and rights to payments for working natural resources, excluding ships, boats and aircraft. The rule covers income from direct use, letting or other forms of use, income of enterprises from immovable property, income used for independent personal services, and income to owners entitled to enjoyment of property through shares or other rights, notwithstanding provisions governing business or service income.
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 may be taxed in the State where the property is situated, including enjoyment through ownership rights.
Income derived by a resident from immovable property situated in the other Contracting State 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, agricultural assets, usufruct and rights to payments for working natural resources, excluding ships, boats and aircraft. The rule covers income from direct use, letting or other forms of use, income of enterprises from immovable property, income used for independent personal services, and income to owners entitled to enjoyment of property through shares or other rights, notwithstanding provisions governing business or service income.
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