Income Accrued from Property Assets
(1) Income accrued from property assets is taxable in the contracting state in which such assets exist.
(2) The phrase "property assets" is defined in accordance with the law of the contracting state in which such assets exist. And under all conditions such phrase encompasses assets pertinent to property assets such as the equipment used in agriculture and plantations that are governed by the provisions of the general law regarding ownership of lands, usufruct of property assets, right in changing or fixed funds in return of use or the right of use of warehouses, metals or other natural resources. Ships and aircraft are not considered as property assets.
(3) The provisions of paragraph (a) apply to income accrued from direct use of property assets, lease or use thereof in any other manner.
(4) The provisions of paragraph (1) and paragraph (3) also apply to income accrued from property assets that are owned by the project and income accrued from property assets that are used for performance of professional services.