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

May 15, 2026

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

Puntos clave

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.

Resumen

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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Cite This Study

JoelA. Nitikman (Wed,) studied this question.

synapsesocial.com/papers/6a06b86ae7dec685947aaeea https://doi.org/https://doi.org/10.59403/2s4e5c3