МЕЖДУ ПРАВИТЕЛЬСТВОМ РОССИЙСКОЙ ФЕДЕРАЦИИ И ПРАВИТЕЛЬСТВОМ БОЛИВАРИАНСКОЙ РЕСПУБЛИКИ ВЕНЕСУЭЛА ОБ ИЗБЕЖАНИИ ДВОЙНОГО НАЛОГООБЛОЖЕНИЯ И ПРЕДОТВРАЩЕНИИ УКЛОНЕНИЯ ОТ НАЛОГООБЛОЖЕНИЯ В ОТНОШЕНИИ НАЛОГОВ НА ДОХОДЫ И КАПИТАЛ. Конвенция. Правительство РФ. 22.12.03

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 State may be taxed in that other
State.
     2.  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,  livestock  and  equipment used in
agriculture  and  forestry,  rights to which the provisions of general
law  respecting  landed  property  apply,  rights known as 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 and aircraft
shall not be regarded as immovable property.
     3.  The  provisions  of paragraph 1 shall apply to income derived
from  the  direct  use, letting, or use in any other form of immovable
property.
     4.  The  provisions  of paragraph 1 and 3 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.