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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) situated in the other Contracting State may be taxed in that other State.

(2) The term "immovable property" shall have the meaning which it has under the law of the Contracting State where the goods are at issue. The term shall in any case include property accessory to immovable property, livestock and equipment used in agriculture and forestry, rights to which they apply the provisions of general law respecting landed property apply, usufruct of immovable property and rights to receive payments, fixed or variable for the working or mineral deposits, sources and other natural resources including oil, gas and quarries. Ships, boats and aircraft shall not be regarded as immovable property.

(3) The provisions of paragraph (1) shall apply to income derived from the direct use, letting, or any other use of real property.

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