Interpretation of Article 15(2)(b) of the OECD Model Convention : "remuneration paid by, or on behalf of, an employer who is not a resident of the other state"

Journal
Bulletin for International Taxation 2000 (Volume 54), No. 10
The authors consider the interpretation of Art. 15(2)(b) of the OECD Model Convention, in particular, in cases of cross-border secondment of employees. Only cases of bona fide cross-border secondment are considered.