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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.

ARTICLE 6

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 in which the property in question is situated. The term shall in any include property accessory to immovable property, livestock and equipment used in agriculture and forestry, rights to which the provisions of general law respecting landed property apply, usufruct of immovable property and rights to variables or fixed payments as consideration for the working of, or the right to work, mineral deposits, sources and other natural resources; The ships and aircraft shall not be considered immovable property.

(3) The provisions of paragraph (1) of this Article shall also apply to the income derived from the direct use, letting 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.

(5) The above provisions shall also apply to income derived of movable property or to the income received for services provided in connection with the use or the granting of the use of immovable property which, according to the tax law of the Contracting State in which such goods are located, are assimilated to income derived from movable property.