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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 the other State.

(2) The term "immovable property" shall be defined in accordance with the law of the Contracting State that includes such property, and such term shall include, in all cases, other properties related to the immovable properties, livestock, equipments used in agriculture, the rights to which the provisions of the general law on immovable property ownership are applied, usufruct of immovable property, and the right to fixed or changing payments against the use or the right to use mineral resources or any other natural resources. The ships, boats and aircrafts may not be considered immovable property.

(3) The provisions of paragraph (1) of this Article shall also apply to income derived from the direct use, lease or use in any other form of immovable property.

(4) The provisions of paragraph (1) and (3) of this Article shall also apply to income from immovable property of enterprises and to income from immovable property used to render independent personal services.