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

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.