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 24
Taxation Regulations
(1) Immovable property forming part of the estate of, or a gift by, a resident of a Contracting State and situated in the other Contracting State shall be taxable in that other State.
(2) Immovable property of an enterprise forming part of the estate of, or a gift by, a resident of a Contracting State, and
- (a) Constituting the operating capital of a permanent establishment situated in the other Contracting State, or
- (b) Pertaining to the exercise of a profession or other independent personal services and forming part of a fixed base situated in the other State may be taxed in that other State.
(3) All other property forming part of the estate of, or a gift by, a resident of a Contracting State, irrespective of its location, shall be taxable only in that State, unless Article 26 otherwise provides.