Income from immovable property may be taxed where the property is situated; definition includes rights and resource payments. Income derived by a resident from immovable property situated in the other Contracting State may be taxed in that other State. 'Immovable property' is defined by the law of the State where the property is situated and includes accessories, livestock and equipment used in agriculture and forestry, usufruct, and rights to payments for working or the right to work mineral deposits and other natural resources, while excluding ships and aircraft. The taxation rule covers direct use, letting or other forms of use and applies to enterprise income and income 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 may be taxed where the property is situated; definition includes rights and resource payments.
Income derived by a resident from immovable property situated in the other Contracting State may be taxed in that other State. "Immovable property" is defined by the law of the State where the property is situated and includes accessories, livestock and equipment used in agriculture and forestry, usufruct, and rights to payments for working or the right to work mineral deposits and other natural resources, while excluding ships and aircraft. The taxation rule covers direct use, letting or other forms of use and applies to enterprise income and income used for independent personal services.
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