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ARTICLE 6

U.S. Income Tax Treaty — United States Model Income Tax Treaty - 1996 · 2026-10-03 edition · updated 2026-10-04 · United States

Income from Real Property (Immovable Property)

  1. Income derived by a resident of a Contracting State from real property (immovable property), including income from agriculture or forestry, situated in the other Contracting State may be taxed in that other State.

  2. The term "real property (immovable property)" shall have the meaning which it has under the law of the Contracting State in which the property in question is situated.

  3. The provisions of paragraph 1 shall apply to income derived from the direct use, letting, or use in any other form of real property.

  4. The provisions of paragraphs 1 and 3 shall also apply to the income from real property of an enterprise and to income from real property used for the performance of independent personal services.

  5. A resident of a Contracting State who is liable to tax in the other Contracting State on income from real property situated in the other Contracting State may elect for any taxable year to compute the tax on such income on a net basis as if such income were business profits attributable to a permanent establishment in such other State. Any such election shall be binding for the taxable year of the election and all subsequent taxable years unless the competent authority of the Contracting State in which the property is situated agrees to terminate the election.

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▸Contents — U.S. Income Tax Treaty — United States Model Income Tax Treaty - 1996
U.S. Income Tax Treaty — United States Model Income Tax Treaty - 1996

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