Article 6Income 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 that other 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. For the purposes of this Convention property accessory to immovable property, in particular buildings, livestock and equipment used in agriculture and forestry, rights to which the provisions of general law respecting landed property apply, in particular any options or similar right to acquire immovable property, 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 shall also be treated as immovable property; 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, letting, or use in any other form of immovable property.
(4) Where the ownership of shares or other corporate rights in a company entitles the owner of such shares or corporate rights to the enjoyment of immovable property held by the company, the income from the direct use, letting, or use in any other form of such right to enjoyment may be taxed in the Contracting State in which the immovable property is situated.
(5) The provisions of paragraphs (1), (3) and (4) 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.