background image
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.

ARTICLE 6

Income from Immovable Property

(1) Income derived by a resident of a Contracting State from immovable property, including income from agricultural or forestry operations situated in the other Contracting State shall be taxed in that other State.

(2) The term "immovable property" shall have the meaning that it has under the law of the Contracting State in which the property in question is situated. The term shall in any case include property accessory to immovable property, livestock and equipment used in agricultural and forestry operations, rights to which the provisions of general 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 at sites of mineral deposits, sources and other natural resources. Ships, boats and aircraft shall not be regarded as immovable property.

(3) The provisions of paragraph (1) of this Article, shall apply to income derived from the direct use or enjoyment, letting, leasing as well as 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 as well as to income from immovable property used for the performance of independent personal services.