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Germany - Russia Tax Treaty (as amended by 2007 protocol) — Orbitax Tax Hub

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 Properties

(1) Income derived by a person resident in one Contracting State from immovable property (including income from agriculture and forestry operations) situated in the other Contracting State may be taxed in the other State.

(2) The term "immovable property" shall have the meaning according to the law of the Contracting State where the property is situated. In any case the expression shall cover property accessory to immovable property, livestock and equipment used in agricultural and forestry operations, rights to which the provisions of general law respecting landed property apply, usufruct of immovable property as well as the right to variable or fixed payment for the mining or the right to mine mineral deposits, sources and other natural resources; ships and aircrafts shall not be regarded as immovable property.

(3) The provisions of Paragraph (1) shall apply to income from the direct use, renting or leasing as well as any other form of use of immovable property.

(4) Paragraphs (1) and (3) also apply to income from immovable property of an enterprise and for income from immovable property that was used for the performance of independent personal services.