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Note: This Treaty may be impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). MLI impact on Tax Treaties is available with the Orbitax International Tax Research & Compliance Expert.


Income from Immovable Property

(1) The income generated by immovable property owned by a resident in a Contracting States, including agricultural income and forestry, shall be taxable in that State where such assets exist.

(2) The term "immovable property" shall be defined in accordance with the law of the Contracting State that includes such assets, and such term shall include, in all cases, other assets related to the immovable property  livestock, equipment used in agriculture and forestry, the rights to which the provisions of the general law on real estate property ownership are applied, as well as the usufruct of immovable property, and the rights to fixed or changing payments against the use (or the right to use) mineral resources or any other natural resources. The ships, boats and aircraft may be considered movable assets.

(3) The provisions of the above-mentioned paragraph (1) shall apply to the income of the direct use, renting, or any other form of immovable property use.

(4) The provisions of the abovementioned paragraphs (1) and (3) hereof shall also apply to the income of any enterprise unmovable property and immovable property used for performing independent personal services.

(5) The provisions of this Article shall not apply to the investment activities practiced by governmental and semi-governmental institutions, provided that such profits are subject to tax in the headquarters country.