Income from immovable property may be taxed only in the state where the property is situated. Income from immovable property is taxable only in the Contracting State where the property is situated; this rule covers income from direct use, letting or other use, and applies equally to income of an enterprise and to income from immovable property used for independent personal services. The term immovable property is defined by the law and usage of the State where the property is situated and includes accessories, agricultural and forestry livestock and equipment, usufruct, and rights to payments for working mineral deposits and other extraction sites, while excluding ships and aircraft.
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 only in the state where the property is situated.
Income from immovable property is taxable only in the Contracting State where the property is situated; this rule covers income from direct use, letting or other use, and applies equally to income of an enterprise and to income from immovable property used for independent personal services. The term immovable property is defined by the law and usage of the State where the property is situated and includes accessories, agricultural and forestry livestock and equipment, usufruct, and rights to payments for working mineral deposits and other extraction sites, while excluding ships and aircraft.
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