Income from Immovable Property
(1) The income generated by immovable property owned by a resident in a Contracting States, including agricultural income and forestry, shall be taxable in that State where such property exist.
(2) The term “immovable property” shall be defined in accordance with the law of the Contracting State that includes such property, and such term shall include, in all cases, other property related to the immovable property, livestock, equipment used in agriculture and forestry, the rights to which the provisions of the general law on real estate property ownership are applied, as well as the usufruct of immovable property, and the rights to fixed or changing payments against the use (or the right to use) mineral resources or any other natural resources. The ships, boats and aircrafts may be considered movable property.
(3) The provisions of the abovementioned paragraph (1) shall apply to the income of the direct use, renting, or any other form of immovable property use.
(4) The provisions of the abovementioned paragraphs (1) and (3) hereof shall also apply to the income of any enterprise immovable property and immovable property used for performing independent personal services.