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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 from immovable property (including income from agricultural or forestry operations) may be taxed in the Contracting State in which such property is situated.

(2) For the purposes of this Convention, 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 at sites for exploitation or exportation of mineral deposits and other natural resources. Ships 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 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) Notwithstanding the provisions of Articles 7 and 14 of this Convention, where a person owns shares or other rights in a corporation, guarantee company or a similar company granting him/her the right of enjoyment with respect to immovable property situated in a Contracting State and held by that company, guarantee company or a similar company, any income from the direct use or letting or use in any other form of his or her right of enjoyment shall be taxable in that Contracting State.