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HMRC internal manual

International Manual

Description of double taxation agreements: Income from immovable property

The Article dealing with income from immovable property gives the primary taxing rights to the country in which the property is situated. But the income is also taxable in the country of residence of the taxpayer. In the United Kingdom `immovable property’ means, generally, land, the buildings erected on land, minerals in the soil and rights over land.

The Article also includes in the definition livestock and equipment used in agriculture and forestry. `Income’ includes income from the direct use, letting etc. of immovable property. It also includes income from agriculture and forestry. When calculating the amount of United Kingdom farming profits in the case of a farming trade carried on in the United Kingdom and in a country with which the United Kingdom has a double taxation agreement, the principles set out in the business profits Article for the allocation of income and expenses should be used.