Income from Immovable Property
(1) Income derived by a resident of a Contracting State from immovable property (including income from agriculture or forestry) situated in the other Contracting State may be taxed in that other Contracting State.
But the tax so charged shall be reduced to 50% if beneficiary owner of the income derived from immovable property is the State itself or local authorities, political subdivision, local Governments or local financial institutions are belong to the Contracting State.
(2) The term "immovable property" shall have the meaning, which it has under the national laws of the Contracting State in which the property in question is situated. The term shall in any case include property accessory to immovable property, livestock and equipment used in agriculture and forestry, rights to which the provisions of general laws respecting landed property apply, usufruct of immovable property and rights to variable or fixed payments as consideration for the working of, or the right of work, mineral deposits, sources and other natural resources; ships and aircraft shall not be regarded as immovable property.
(3) The provisions of paragraph (1) of this Article shall apply to income derived from the direct use, letting, or use in any other term of immovable property.
(4) The provisions of paragraphs (1) and (3) of this Article shall also apply to income from immovable property of an enterprise and to income from immovable property used for the performance of independent personal services.
(5) The provisions of paragraphs (3) shall not apply if the beneficial owner of the income is the State itself or local authorities, political subdivision, local Governments or their financial institution.