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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.

ARTICLE 6

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 State.

(2) For the purposes of this Convention, the term "immovable property" shall mean the ground surface land as well as buildings. 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 law in respect of 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 and sources from other natural resources. However, the preceding clause shall be implemented only if the domestic laws of the Contracting State have a corresponding provision. 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, leasing or use in any other form 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 as well as to income from immovable property used for the performance of independent personal services.