Taxation of immovable property: income from property situated abroad may be taxed in the source state. Income paid to a resident of one Contracting State from immovable property situated in the other Contracting State may be taxed in that other State. 'Immovable property' is determined by the law of the State where the property lies and includes accessories, agricultural livestock and equipment, landed property rights, usufruct and payments for working mineral and other natural resources, but excludes ships, boats and aircraft. The rule covers income from direct use, letting or other uses and applies to enterprise property income and property 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.
Taxation of immovable property: income from property situated abroad may be taxed in the source state.
Income paid to a resident of one Contracting State from immovable property situated in the other Contracting State may be taxed in that other State. "Immovable property" is determined by the law of the State where the property lies and includes accessories, agricultural livestock and equipment, landed property rights, usufruct and payments for working mineral and other natural resources, but excludes ships, boats and aircraft. The rule covers income from direct use, letting or other uses and applies to enterprise property income and property used for independent personal services.
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