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Article 7. INCOME FROM REAL PROPERTY

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

Under paragraph (1 ), income from real property, including royalties and other payments in respect of the exploitation of natural resources (e.g., .oil wells), and gains from the alienation (sale, exchange or other disposi­ tion)of such property or of the right giving rise to such royalties or other payments may be taxed by the Contracting State in which the real property

or natu,,,1 resources are situated, For purposes of the Convention. interest on 'L1Jebtedness secured l:!Y real property (e.g., mortgages) or secured by a right giving rise to royalties or other payments in respect of the exploitation of natural resources are not considered as income trom real property,

, Under paragraph (2). paragraph (1) applies 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 — Technical Explanation - 1976

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