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

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.