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HMRC internal manual

Double Taxation Relief Manual

From
HM Revenue & Customs
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DT: Trinidad and Tobago: double taxation agreement, Article 6: Income from immovable property

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

(2) The term `immovable property` shall have the meaning which it has under the law of theContracting State in which the property in question is situated. The term shall in anycase include property accessory to immovable property, livestock and equipment used inagriculture and forestry, rights to which the provisions of general law respecting landedproperty apply, usufruct of immovable property and rights to variable or fixed payments asconsideration for the working of, or the right to work, mineral deposits, sources andother natural resources; ships, boats and aircraft shall not be regarded as immovableproperty.

(3) The provisions of paragraph (1) of this Article shall apply to income derived from thedirect use, letting, or use in any other form of immovable property.

(4) The provisions of paragraphs (1) and (3) of this Article shall also apply to theincome from immovable property of an enterprise and to income from immovable property usedfor the performance of independent personal services.