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

JoelA. Nitikman

doi:10.59403/a307hq

May 12, 2026Bulletin for international taxation

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

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Key Points

To clarify the interpretation of 'borne by' in Article 15(2)(c) of the OECD Model and its implications.
Analyzed the wording and context of Article 15(2)(c) in the OECD Model and its Commentary.
Examined relevant legal interpretations and practical implications for permanent establishments.
Concluded that 'borne by' means that employment income should be deductible by the permanent establishment.
Identified discrepancies in the current interpretation of the term within the OECD Commentary.

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Implication

Article analyzes the interpretation of 'borne by' in OECD Model's Article 15, indicating implications for income deduction.

Abstract

Article 15 of the OECD Model governs employment income. This article suggests that the meaning of “borne by” in the OECD Commentary to Article 15(2)(c) of the OECD Model is incorrect; the term means that the employment income must be deductible by the permanent establishment (PE) in computing its income.

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JoelA. Nitikman (2026) studied this question.

synapsesocial.com/papers/6a056767a550a87e60a1f60f https://doi.org/10.59403/a307hq

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

Key Points

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Implication

Abstract

Discussion

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

Key Points

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Implication

Abstract

Discussion

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