DT6720.6 - DT: Estonia: double taxation
agreement, Article 6: Income from immovable property
Income derived by a resident of a Contracting State from
immovable property (including income from agriculture or forestry)
situated in the other Contracting State may be taxed in that other
State.
The term `immovable property` shall have the meaning which it
has under the law of the Contracting State in which the property in
question is situated. The term shall in any case include property
accessory to immovable property, in particular buildings, livestock
and equipment used in agriculture and forestry, rights to which the
provisions of general law respecting landed property apply, in
particular any options or similar right to acquire immovable
property, 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 of this Article shall apply to
income derived from the direct use, letting, or use in any other
form of immovable property.
Where the ownership of shares or other corporate rights in a
company entitles the owner of such shares or corporate rights to
the enjoyment of immovable property held by the company, the income
from the direct use, letting, or use in any other form of such
right to enjoyment may be taxed in the Contracting State in which
the immovable property is situated.
The provisions of paragraphs 1, 3 and 4 of this Article 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.
