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ARTICLE 7

U.S. Income Tax Treaty — Philippines Income Tax Treaty - 1976 · 2026-10-03 edition · updated 2026-10-04 · United States

Income from Real Property

(1) Income from real property, including royalties and other payments in respect of the exploitation of natural resources and gains derived from the alienation of such property or of the right giving rise to such royalties or other payments, may be taxed by the Contracting State in which such real property or natural resources are situated. For purposes of this Convention, interest on indebtedness secured by real property or secured by a right giving rise to royalties or other payments in respect of the exploitation of natural resources shall not be regarded as income from real property.

(2) Paragraph (1) shall apply to income derived from the usufruct, direct use, letting, or use in any other form of real property.

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▸Contents — U.S. Income Tax Treaty — Philippines Income Tax Treaty - 1976

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