The Meaning of “Borne by” in Article 15(2)(c) of the OECD Model: Part Two

Key Points

• The aim is to clarify the interpretation of the phrase 'borne by' in Article 15(2)(c) of the OECD Model as it pertains to employment income and tax treatment.
• Analysis of the OECD Model, particularly Article 15 on employment income.
• Review of the OECD Commentary regarding the phrase in question.
• Demonstrated that the current interpretation by the OECD Commentary is incorrect.
• Argued that 'borne by' necessitates that employment income is deductible.