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CHAPTER I - Scope of the Arrangement
CHAPTER II - Definitions
CHAPTER III - Taxation of Income
CHAPTER IV - Avoidance of Double Taxation
CHAPTER V - Special Provisions
CHAPTER VI - Final Provisions
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 country from immovable property, including income from agriculture or forestry, situated in the other country may be taxed in that other country.

(2) The term "immovable property" shall have the meaning which it has under the law of the country 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 agriculture and forestry, 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) Rights to the exploration and exploitation of natural resources shall be regarded as immovable property located in the country to whose seabed and the subsoil thereof these rights apply. For the purposes of Articles 5, 7 and 13, such rights are regarded as assets of a permanent establishment in that country. The aforementioned rights also include rights or interests in, or benefits from, assets arising from such exploration or exploitation.

(4) The provisions of paragraph (1) shall apply to income derived from the direct use, letting, or use in any other form of immovable property.

(5) This Article shall also apply to the income from immovable property of an enterprise.