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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 who is resident in one Contracting State draws from immoveable property (including earnings from agricultural and forestry operations), that are located in the other Contracting State can be taxed in the other.

(2) The term "immoveable property" has the meaning that it has under the laws of the Contracting State in which the assets are located. The term includes in every case the accessories for the immoveable properties, the living and dead inventory of agricultural and forestry operations, the rights for which the regulations of private law on real estate properties, use rights to immoveable assets as well as rights to changeable or fixed compensations for the exploitation or the right to exploit mineral deposits, wells, and other mineral resources. Ships and aircraft are not deemed to be immoveable assets.

(3) Paragraph (1) applies to earnings from direct use, the leasing or rental as well as any other type of use of immoveable assets.

(4) The paragraphs (1) and (3) also apply to earnings from immovable assets of some business and earnings from immovable assets that serve the exercise of freelance employment.