- 1. Income derived from immovable property (including income from agriculture or forestry) situated in a Contracting State may be taxed in that State.
- 2. 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 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, aircraft and railway vehicles 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.
- 5. Where shares or other rights in a company, other legal person, partnership, trust or any similar body give an entitlement to enjoy immovable property situated in a Contracting State and held by that company, other legal person, partnership, trust or similar body, income derived from the direct use, letting, or use in any other form of that entitlement to enjoy, may be taxed in that State notwithstanding the provisions of Article
7.