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This article examines the interpretation of 'borne by' in OECD Model Article 15 regarding employment income, implying a need for deductibility for permanent establishments.
In Part Two of this article, the author continues to explore article 15 of the OECD Model as it applies to employment income. The author maintains that the OECD Commentary misinterprets the phrase “borne by” and that it should instead be understood as requiring that the employment income be deductible by the permanent establishment in computing its income.
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JoelA. Nitikman (2026) studied this question.
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