Immovable property taxation: income from property taxable where property is located under tax treaty, including agricultural and mineral rights. Income from immovable property derived by a resident of one Contracting State may be taxed in the State where the property is situated. Immovable property is defined by the law of the State where the property lies and includes accessories, livestock and equipment used in agriculture and forestry, rights governed by landed property law, usufruct, and payments for working or rights to work mineral deposits and other natural resources; ships, boats, aircraft and motor vehicles are excluded. The rule covers direct use, letting or other use and applies to enterprise income and income linked to 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 taxation: income from property taxable where property is located under tax treaty, including agricultural and mineral rights.
Income from immovable property derived by a resident of one Contracting State may be taxed in the State where the property is situated. Immovable property is defined by the law of the State where the property lies and includes accessories, livestock and equipment used in agriculture and forestry, rights governed by landed property law, usufruct, and payments for working or rights to work mineral deposits and other natural resources; ships, boats, aircraft and motor vehicles are excluded. The rule covers direct use, letting or other use and applies to enterprise income and income linked to independent personal services.
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