Article 15 of the OECD Model: The 183-Day Rule and the Meaning of “Borne by a Permanent Establishment”

Article 15(2) of the OECD Model is important in taxing employment income in regard to a short-term assignment of employees and the hiring-out of labour. This article examines the object and purpose of the 183-day rule, when the remuneration is paid by, or on behalf of, an employer and when borne by a permanent establishment.