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(1) Income derived by a resident of a Contracting State from real 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” shall have the meaning which it has under the law of the Contracting State in which the properly in question is situated. The term shall in any case include properly accessory to real property, livestock and equipment used in agriculture and forestry, rights to which the provisions of general law respecting landed property apply, usufruct of real property and rights to variable or fixed payments as consideration for the working of, or the right to work, or the right to explore for, mineral deposits, sources and other natural resources; ships, boats and aircraft shall not be regarded as real 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 real property.
(4) Any interest or right referred to in paragraph (2) shall be regarded as situated where the land, mineral deposits, sources and other natural resources, as the case may be, are situated or where the exploration may take place.
(5) The provisions of paragraphs (1) and (3) of this Article 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.
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