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.