Belgian Ruling Commission’s Opinion of the Concept of "Employer" within the Meaning of Article 15 of the OECD Model

The author discusses a recently published ruling of the Belgian Ruling Commission on a number of implementation measures contained in article 15 of the OECD Model (2010), in particular, whether substance should prevail over form in defining the concept of "employer" for the purposes of article 15, as well as the "by or on behalf of" criterion.