Income from Immovable Property or Real Property
(1) Income derived by a resident of a Contracting State from immovable property (including income from agriculture or forestry operations) 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 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 respecting 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 and aircraft shall not be regarded as immovable property.
(3) The provisions of paragraph (1) above shall apply to income derived from the direct use, letting, leasing or use in any other form of immovable property.
(4) The provisions of paragraphs (1) and (3) above 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.
(5) Notwithstanding the provisions of Article 7, the preceding provisions of this Article shall also apply to income from movable property or to income from services related to the use or right to use immovable property which, according to the tax law of the Contracting State in which such property is situated is assimilated to income from immovable property.