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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 Contracting State.

(2) The expression "immovable property" shall have the meaning that it has under the laws of the Contracting State in which the property is situated. The expression 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 in respect of 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, vessels 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 use in any other form of immovable property.

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