INCOME FROM IMMOVABLE PROPERTY
(1) Income derived by a resident of a Contracting State from immovable property situated in the other Contracting State may be taxed in that other State provided that the tax does not exceed 10% of the value of income.
(2) The term "immovable property" shall have the meaning which it has under the law of the Contracting State in which the property in question is situated. The term shall in any case include property accessory to immovable property, rights to which the provisions of general law respecting landed property apply, usufruct of immovable property and rights to variable or fixed payments as consideration for the working of, or the right to work, mineral deposits, sources and other natural resources. Ships and aircraft shall not be regarded as immovable property.
(3) The provisions of paragraph 1 shall apply to income derived from the direct use, letting, or use in any other form of immovable property.
(4) The provisions of paragraphs 1 and 3 shall also apply to the 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 1, 3 and 4 shall also apply to the income from State institutions.