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Income from immovable property may be taxed in the State where the property is situated under the DTAA. Income derived by a resident from immovable property situated in the other Contracting State may be taxed in that State, including income from agriculture and forestry and income from direct use, letting or other forms of use. 'Immovable property' is defined by the law of the State where the property is located and includes accessories to land, livestock and equipment used in agriculture and forestry, rights subject to landed property law, usufruct, and rights to payments for working or the right to work mineral deposits and natural resources; ships, boats and aircraft are excluded. The rule also applies to enterprise income and income used for independent personal services.
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Provisions expressly mentioned in the judgment/order text.
Income from immovable property may be taxed in the State where the property is situated under the DTAA.
Income derived by a resident from immovable property situated in the other Contracting State may be taxed in that State, including income from agriculture and forestry and income from direct use, letting or other forms of use. "Immovable property" is defined by the law of the State where the property is located and includes accessories to land, livestock and equipment used in agriculture and forestry, rights subject to landed property law, usufruct, and rights to payments for working or the right to work mineral deposits and natural resources; ships, boats and aircraft are excluded. The rule also applies to enterprise income and income used for independent personal services.
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