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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 from immovable property situated in the Contracting State are taxable in that Contracting State.

(2) The term "immovable property" is defined in accordance to the laws of the Contracting State where the property is situated. The term shall in any case include property accessory to immovable property, livestock and equipment used in agriculture and forestry, rights to which the provisions of private law respecting 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; ships, boats, and aircraft shall not be regarded as immovable property.

(3) The provisions of paragraph (1) shall apply equally to incomes arising from the direct use, the hiring or leasing, as well as every other form of exploitation of the immovable property.

(4) The provisions of paragraphs (1) and (3) shall also apply to income from immovable property of an enterprise and the income from the immovable property used for the exercise of an independent personal service.