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

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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Publication Details

Journal
Bulletin for international taxation
Published
2026-05-12
DOI
https://doi.org/10.59403/a307hq
Primary Topic
International Labor and Employment Law
Type
article
Field-Weighted Citation Impact
0.00
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article

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

JoelA. Nitikman
Bulletin for international taxation
International Labor and Employment Law
article

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

JoelA. Nitikman
article en

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.

Bulletin for international taxationVol. 80(6)
Decent work and economic growth
Openalex Percentile: Top 3%
International Labor and Employment Law
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The Meaning of “Borne by” in Article 15(2)(c) of the OECD Model: Part One — JoelA. Nitikman · Bulletin for international taxation (2026) | TGRS Research Map | TGRS