Par. 4 of the Commentary on art. 21 (other income) of the OECD Model deals with the case where an enterprise of one contracting state owns immovable property which is situated in the same contracting state, but forms part of the property of the permanent establishment (PE) in the other contracting state through which the enterprise carries on business in that other state. According to the Commentary, the income derived from the immovable property is taxable only in the state in which the property is situated and in which the recipient of the income is resident. The state in which the PE is situated is not allowed to tax the income even though the immovable property is effectively connected with the PE. This article examines whether this view is in conformity with the wording of the OECD Model.