Article 6 of the OECD Model Treaty provides that income from immovable property may be taxed in the state in which the property is situated. Taxing rights are thus given to both states. Immovable property is given the meaning under the law of the contracting state in which the property is situated. The OECD Model was amended in 1977 to specify that income from immovable property includes income from agriculture or forestry. Article 6(1) of the Ethiopia-UK Income Tax Treaty is representative:

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