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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.


Income from Immovable Property

(1) Income from immovable property (including income from agriculture or forestry) is taxed in the Contracting State in which such immovable property is situated in accordance with the laws of that State.

(2) For the purposes of this Agreement, the term "immovable property" shall have the meaning which it has under the laws 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 agriculture and forestry, rights to which the provisions of the 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, or to explore for, mineral deposits, sources and other natural resources. Ships, boats or aircraft shall not be regarded as immovable property.

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

(4) The provisions of paragraphs (1) and (3) 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) Where the ownership of shares or other rights in a company, trust or comparable institution is thereby entitled to the enjoyment of immovable property situated in a Contracting Company and held by that company, trust or comparable institution, income from direct use, letting, or use in any other form of such a right of enjoyment by that person may be taxed in that State notwithstanding the provisions of Articles 7 and 14.