Immovable property income can be taxed in the State where the property is situated under the treaty. Income derived 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 located. 'Immovable property' is defined by the law of the State in which the property is situated and includes property accessory, livestock and equipment used in agriculture and forestry, landed-property rights, buildings, usufruct, and rights to payments for working or the right to work natural resources; ships, boats and aircraft are excluded. The rule applies to direct use, letting or other forms of use and covers enterprise property income and property used to perform 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.
Immovable property income can be taxed in the State where the property is situated under the treaty.
Income derived 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 located. "Immovable property" is defined by the law of the State in which the property is situated and includes property accessory, livestock and equipment used in agriculture and forestry, landed-property rights, buildings, usufruct, and rights to payments for working or the right to work natural resources; ships, boats and aircraft are excluded. The rule applies to direct use, letting or other forms of use and covers enterprise property income and property used to perform independent personal services.
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