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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) The income that a resident of a Contracting State earns from immovable properties, including incomes from agricultural and forestry activities located in the other Contracting State shall be taxable in that other State.


  • (a) Subject to the provisions of sub-paragraphs (b) and (c), the term "immovable properties" shall be defined in accordance to the laws of the Contracting State where the property in question is located.
  • (b) The term "immovable property" shall in any case include property accessory to immovable property, live stock and equipment used in agriculture and forestry and rights to which the provisions of general law respecting landed property apply, usufruct of immovable property, 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.
  • (c) Ships, boats and aircraft shall not be deemed as immovable properties.

(3) The provisions of paragraph (1) shall apply to income derived from the direct use, letting or leasing, or use in 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.