Taxation of immovable property limited to the state where the property is situated, covering letting, use, and enterprise income. Income from immovable property is taxable only in the Contracting State where the property is situated. 'Immovable property' is defined by the law and usage of that State and includes accessories to land, agricultural and forestry assets, certain rights including usufruct and payments for working natural resources, while excluding ships and aircraft. The territorial taxation rule covers income from direct use, letting, or other use of the property and applies to enterprise property and property used to provide professional services.
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Provisions expressly mentioned in the judgment/order text.
Taxation of immovable property limited to the state where the property is situated, covering letting, use, and enterprise income.
Income from immovable property is taxable only in the Contracting State where the property is situated. "Immovable property" is defined by the law and usage of that State and includes accessories to land, agricultural and forestry assets, certain rights including usufruct and payments for working natural resources, while excluding ships and aircraft. The territorial taxation rule covers income from direct use, letting, or other use of the property and applies to enterprise property and property used to provide professional services.
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