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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) 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 that other State.

(2) The expression "immovable property" shall have the meaning which it has under the laws of the Contracting State in which the property in question is situated. The expression includes in all cases the property accessory to the immovable property, the livestock and equipment used in agricultural and forest activities, rights to which the provisions of private 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, sources and other natural resources; oceanic vessels, ships and aircraft are not considered immovable property.

(3) The provisions of paragraph (1) shall apply to the income arising from the direct use or the letting as well as use in any other form of immovable property.

(4) The provisions of paragraphs (1) and (3) also apply to incomes arising from the immovable property of an enterprise.