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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 resident of a Contracting State from immovable property (including income from agriculture or forestry) a State may be taxed in the Contracting State in which such property is situated.

(2) The term "immovable property" shall have the meaning which it has under the law of the Contracting State in which the property is situated. The term shall in any case include property accessory to immovable property, livestock and agriculture and forestry, rights to which the provisions of general law respecting landed property apply, usufruct of immovable property and rights to variable payments or for the working of, or the right to work, mineral deposits, oil or gas, careers sources and other natural resources including forest products. Ships, boats, aircraft and road or railway vehicles are not considered property.

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

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