ARTICLE 6
U.S. Income Tax Treaty — Thailand Income Tax Treaty - 1996 · 2026-10-03 edition · updated 2026-10-04 · United States
Income from Immovable (Real) Property
Income derived by a resident of a Contracting State from immovable (real) property (including income from agriculture or forestry) situated in the other Contracting State may be taxed in that other State.
The terms "immovable property" or "real property" shall have the meanings which they have under the law of the Contracting State in which the property in question is situated. The terms 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, boats and aircraft shall not be regarded as immovable property.
The provisions of paragraph 1 shall apply to income derived from the direct use, letting, or use in any other form of immovable property.
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.
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