I have a property in Italy that is currently rented. I'm paying 10% in taxes as rent is at a rate agreed with the local council. According to the UK/Italy double taxation convention, it seems to me that the income from immovable property should be taxed only in one country. Is this correct? Do I have to declare this to HMRC?

Details of the Article in question:

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. 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 shall also be considered as "immovable property". Ships, boats and aircraft shall not be regarded as immovable property.

(3) 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.

(4) The provisions of paragraphs (1) and (3) 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

  • 1
    It's a fairly specialised topic so there might not be anyone who knows the details directly. Maybe if you quote the specific passages of the convention that you think mean you only get taxed in Italy, it'd help. May 16, 2023 at 8:25
  • How do you get from "may be taxed in that other State" to "may not be taxed in the first State"? May 17, 2023 at 10:41
  • @GS-ApologisetoMonica "situated in the other Contracting State may be taxed in that other State." As in, if it is the other state (the one you are not resident in) it is taxed there.
    – Blue Moon
    May 17, 2023 at 17:59
  • I don't think that language rules out it being taxed both in Italy and in the UK. Typically in cases like that double taxation treaties allow the tax paid in one place to be deducted from the tax due in the other place. May 17, 2023 at 19:11


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