Date |
Document |
Institution |
MCC |
Or Lan |
§ / Pages |
Summary |
27/05/57 |
FC/WP2(57)1 |
WP2 - FC - OEEC |
DK, LU |
En |
Article I/ 2 |
Draft Article on Fiscal Domicile and its Commentary |
03/03/59 |
FC/WP14(59)1 |
WP14 - FC - OEEC |
AT, SE |
En |
- |
Report containing Draft Article and Commentary |
09/01/61 |
FC/WP14(61)1 |
WP14 - FC - OEEC |
AT, SE |
En |
- |
New Draft Article and its Commentary |
08/07/61 |
FC/M(61)4 |
FC - OEEC |
- |
Fr |
V/ 6 |
Discussion on report FC/WP14(61)1, adoption and amendments of
the various sub-paragraphs of paragraph 1 |
18/09/61 |
FC/WP14(61)2 |
WP14 - FC - OEEC |
AT, SE |
En |
- |
Definition of the terms "person" and
"company"; definition of the term "profits" |
29/09/61 |
FC/M(61)5 |
FC - OEEC |
- |
Fr |
IV/ 4 |
Discussion on report FC/WP14(61)2 |
08/01/62 |
FC/WP14(62)1 |
WP14 - FC - OECD |
AT SE |
En |
~/1-10 |
Consideration of expressions to be defined, and draft
definitions + commentary. The term "profits" intentionally left
undefined. |
26/01/62 |
TFD/FC/137 |
WP14 - FC - OECD |
US DE GR |
Fr & En |
- |
Amendments to Art. 3, 28, 30, 31 proposed by WP14 in
FC/WP14(62)2 are adopted by the FC. |
19/02/62 |
FC/M/(62)1 |
FC |
- |
Fr |
II / 4-5 |
Changes to defintions of "person" and
"company" suggested by WP14 in FC/WP14(62)1 dated 06/01/62
approved; Austrian delegate points out that difficulties may arise from the
definition of an "enterprise" |
19/02/62 |
FC/M/(62)1 |
FC |
- |
Fr |
§ / 4 |
Conflicting definitions of undefined terms in domestic laws of
contracting states should be resolved by MAP. |
28/02/62 |
FC/WP14(62)2 |
WP14 - FC - OECD |
AT SE |
En |
§ / 3 |
Report prepared by WP14 in the
light of the discussions of the FC at its last session in January, 1962;
latest version of Article 3, and Commentary. |
09/04/62 |
FC(62)1 |
FC |
CH US |
En |
§ / 3, 5-7 |
Amendments to Art. 3 proposed by WP14 in FC/WP14(62)2 dated
28/02/62 adopted by the FC. |
11/04/62 |
FC/M(62)2 Part I |
FC - OECD |
- |
Fr |
A, B(a), 2, 3, 4 |
Definitions left unchanged, definition of "professional
services" should be included in the separate article for income from
professional services. Commentary on Art. 3 slightly altered. |
08/06/62 |
FC/M(62)3 |
FC |
- |
Fr |
VI / 10 |
Final text of the Article is adopted by the FC. |
21/02/63 |
FC(63)2 |
FC - OECD |
- |
En & Fr |
§ / 7 |
Latest draft model convention. |
22/05/63 |
TFD/FC/158 |
FC - OECD |
US |
En |
I / 1-2 (App) |
US Criticism: the definition of "an enterprise of a
contracting state" cannot be viewed as a definition. Problems may arise
- need to clearly define the expression "enterprise". |
06/02/67 |
TFD/FC/208 |
FC - OECD |
- |
En |
§ / 10-11 |
Analysis of conformity with or deviation from 1963 Draft OECD
Model in tax treaties signed between July 1963 and July 1966. |
28/02/67 |
TFD/FC/209 |
FC - OECD |
NO SE UK |
- |
§ / 4 |
Observations of member countries about difficulties in the
1963 OECD Draft Convention on income and capital. |
13/03/67 |
TFD/FC/210 |
FC - OECD |
- |
En & Fr |
A / 2 |
1. Should there be a definition of “international traffic” ?
2. Should there be a definition of the territorial scope of the Convention
with a reference, when appropriate, to the continental shelf ? |
13/03/67 |
TFD/FC/210 |
FC - OECD |
- |
En & Fr |
B / 3 |
Outstanding problems of drafting in the 1963 OECD Draft
Convention. |
09/05/67 |
TFD/FC/216 |
FC - OECD |
NO SE UK BE |
En & Fr |
§ / 4 |
Observations of member countries about difficulties in the
1963 OECD Draft Convention on income and capital. This document supercedes
TFD/FC/209 of 28th February, 1967. |
21/07/67 |
TFD/FC/218 |
FC - OECD |
NO SE UK BE DE |
En & Fr |
§ / 7-9 |
Consolidated list of comments made on the OECD Draft
Convention, on which future action may be required. Supercedes TFD/FC/202 dt
14/11/66, TFD/FC/209 dt 28/02/67, TFD/FC/210 dt 13/03/67, and TFD/FC/216 dt
09/05/67. |
25/07/67 |
TFD/FC/219 |
FC - OECD |
GR JP NO |
En & Fr |
§ / 7 |
New WP29 comprising GR JP NO formed for working on Article 8,
including the definition of international traffic, and profits from dredging,
hauling, etc. in high seas. |
25/07/67 |
TFD/FC/219 |
FC - OECD |
AU CH |
En & Fr |
§ / 7 |
New WP30 comprising AU & CH formed for working on Articles
2, 3, 6, 13, 22, and questions concerning partnerships (Art. 1). |
16/09/67 |
TFD/FC/222 |
FC - OECD |
- |
En |
§ / 16-17 |
Analysis of conformity with or deviation from 1963 Draft OECD
Model in tax treaties signed between 01/07/63 and 01/01/67. |
16/05/69 |
DAF/FC/69.8 |
FC - OECD |
- |
En |
16-20/20-23 |
Preliminary analysis of devaitions from the 1963 Draft in tax
treaties signed between 01/07/63 and 01/01/69 - supercedes TFD/FC/222 of
16/09/67. |
27/06/69 |
FC/WP30(69)1 |
WP30 - FC - OECD |
AT CH |
En |
53-71 / 17-22 |
Considerations of WP30 pertaining to the 1963 Draft based on
observations of delegates of member countries and analyses of existing tax
treaties. |
29/12/69 |
DAF/FC/69.17 |
FC - OECD |
- |
En |
a-f / 2-3 |
Discussion of WP30's work on Articles 3 of the 1963 OECD Draft
contained in FC/WP30(69)1 dt 27/06/69: "Enterprise",
"International traffic", continental shelf, "National",
"Resident", "Contracing State" discussed. |
04/06/70 |
FC(70)1 |
FC - OECD |
- |
En |
16-20 / 17-19 |
Analysis of deviations of actual tax treaties concluded
amongst member countries, between 01/07/63 and 01/01/69 from the 1963 OECD
Draft. |
16/12/70 |
DAF/FC/7Q.14 |
FC - OECD |
- |
En |
C / 6 |
Proposals for the amendment of Article 3 and commentaries
thereon, which were agreed to by the Fiscal Committee |
05/03/71 |
DAF/FC/71.5 |
FC - OECD |
- |
Fr |
(b) / 5 |
Note on the discussions at the 38th session of the FC,
examining WP29's report contained in FC/WF29(71)1: Scope of international
traffic. |
24/05/71 |
DAF/FC/71.6 |
FC - OECD |
- |
- |
III / 6-7 |
Notes of discussions at the 39th session of the FC:
Examination of the 3rd Report of WP29 conatined in [FC/WP29(71)2 dt 08/04/71
+ Corrigendum dt 20/04/71]: Scope of international traffic. |
17/06/71 |
CFA/WP1(71)3 |
WP1 - CFA - OECD |
- |
En & Fr |
§ / 2-3, 9-11 |
Latest version of Article and Commentaries. Includes
commentary on the meaning of the word "enterprise". |
22/06/71 |
DAF/CFA/WP1(72)1.3 |
WP1 - CFA - OECD |
- |
? |
II / 4-7 |
WP1's decision to amend the 1963 OECD Draft according upon the
examination of the 4th Report of WG29 [contained in CFA/WP1(71)2 dt 11/06/71
and 22/06/71] on the taxation of shipping and air transport profits. |
23/09/71 |
DAF/CFA/WP1/71.5 |
WP1 - CFA - OECD |
- |
En |
V / 2 |
Invitation of comments about the changes proposed to Articles
3 and 8 about "international traffic" and taxation of profits of
shipping and air transport enterprises. |
28/09/71 |
CFA/WP1(71)5 |
WP1 - CFA - OECD |
- |
En |
§ / 3 |
Changes to the text and commentary of Article 3. |
10/11/71 |
CFA(71)10 |
CFA - OECD |
- |
Fr & En |
§ / 2-3, 12-14 |
Revised text of Article and Commentary as unanimously approved
by the Fiscal Committee or by Working Party N° 1. |
10/02/72 |
CFA(71)10 (1st Revision) |
CFA - OECD |
- |
En & Fr |
§ / 4, 13-16 |
Revised text of Article and Commentary as adopted by WP1
during its 2nd session. Contents of CFA(71)10 dt 10/11/71 revised. |
26/01/73 |
DAF/CFA/WP1/73.2 |
WG28 - WP1 - CFA - OECD |
- |
En |
6 /3 |
The definition of “Nationals”in Article 24 §2 was general and
did not prejudice the application of other articles. The group recommended to
reflect this definition on Article 3. |
15/09/73 |
CFA/VP1(73)9 |
WG30 - WP1 - CFA - OECD |
- |
Fr |
13 / 5-9 |
The treatment of Partnerships under the Provisions of the OECD
Model Convention, Is a Partnership a "Person"? |
14/01/74 |
DAF/CFA/WP1(74)2 |
WP1 - CFA - OECD |
- |
Fr |
III / 3 |
Countries reservations and Working Party amendments to the 2nd
report of Working Group No. 28,
CFA/WP1(73)11 of 5th November, 1973 |
26/01/76 |
CFA/M(77)1 |
CFA - OECD |
- |
En |
3 / 2 |
Decisions taken concerning the 1963 draft double taxation
convention [CFA(76)7 parts I to IV) |
05/11/76 |
DAF/CFA/WP1/76.19 |
WP1 - CFA - OECD |
- |
En & Fr |
§ / 7 |
The revised texts of
the Commentaries on the thirty Articles of the 1963 Draft Convention |
22/11/76 |
CFA (76)7 PART II |
WP1 - CFA - OECD |
- |
- |
§ / 10 |
Revision on the Articles, Commentaries and Reservations of the
1963 Draft Double Taxation convention |
02/12/76 |
CFA(76)7, Part I |
WP1 - CFA - OECD |
- |
- |
- |
PART 1: An examination of the historical background,
implementation of the 1963 model convention , 1977 model convention,
commentaries and articles, multilateral conventions |
10/12/76 |
CFA(76)7 PART II (Corr) |
WP1 - CFA - OECD |
- |
- |
- |
The document contains corrections to the texts issued on 22nd
November, 1976 CFA (76)7 PART II |
30/12/76 |
CFA(76)7, Part IV |
WP1 - CFA - OECD |
- |
- |
§ / 2 |
Part 4: Reservations on the Articles |
01/03/77 |
CFA (76)7part2rev1 |
WP1 - CFA - OECD |
- |
Fr & En |
§ / 10 |
1st revision and final
texts of the articles of the 1977 model double taxation convention adopted by
the committee on fiscal affairs on 18th january 1977 |
04/03/77 |
CFA(76)7 Part III (Corr) |
WP1 - CFA - OECD |
- |
En & Fr |
2 / 3 |
The document observations made by Member countries to the
Commentary |
07/03/77 |
CFA(76)7part1rev1 |
WP1 - CFA - OECD |
- |
En & Fr |
|
1st revision and final version of Part I CFA(76)7, Part I |
11/03/77 |
CFA(76)7part4rev1 |
WP1 - CFA - OECD |
- |
En & Fr |
§ / 2 |
1st revision and final version of Part 4 of the document
CFA(76)7: Reservations on the Articles |
07/10/77 |
DAF/CFA/WP1/77.12 |
WP1 - CFA - OECD |
US |
En |
II / 5 |
The document contains the main differences between the OECD
and the United States Model Convention |
03/05/84 |
DAFFE/CFA/WP1/84.5 |
WP1 - CFA - OECD |
- |
Fr |
Annex I/ 5 |
Discussion on the ruling by the Canadian Supreme Court on the
interpretation of undefined terms |
29/01/87 |
DAFFE/CFA/WP1/87.3 |
WP1 - CFA - OECD |
- |
En |
- |
The document lists several issues related to the referance in
the MC to domestic legislation and the extent to which such legislation can
override the treaty |
21/07/88 |
DAFFE/CFA/WP1/88.7 |
WP1 - CFA - OECD |
- |
Fr |
- |
Report on the provisions of the 1977 MC which should be reviewed |
09/02/89 |
DAFFE/CFA/WP1/89.3 |
WP1 - CFA - OECD |
- |
En |
- |
The note reproduces the observations and reservations to the
1977 MC |
09/08/89 |
DAFFE/CFA/WP1(89)3rev1 |
WP1 - CFA - OECD |
- |
En |
- |
The note reproduces the observations and reservations to the
1977 MC |
29/01/90 |
DAFFE/CFA/WP1/89.3rev2 |
WP1 - CFA - OECD |
- |
En |
§ / 4 |
2nd Revision of the Observations and Reservations of the 1977
Model Convention; Answers received from the letter CFA(88)254 of 3rd October
1988. |
22/03/90 |
DAFFE/CFA/WP1/89.3 rev3 |
WP1 - CFA - OECD |
- |
En |
§ / 4 |
3rd Revision of the Observations and Reservations of the 1977
Model Convention; Answers received from the letter CFA(88)254 of 3rd October
1988. |
26/04/91 |
DAFFE/CFA/WP1/M(91)1 |
WP1 - CFA - OECD |
- |
En |
VI / 6 |
Revision of the 1977 Model;
The Interpretation of terms not defined in the Commentaries was
adopted without change. |
09/08/93 |
DAFFE/CFA/WP1(93)5 |
WP1 - CFA - OECD |
- |
En |
I,A/ 2,11 |
The application of the model tax convention to partnerships,
trusts and other non-corporate entities |
26/08/94 |
DAFFE/CFA/WP1/MR(93)5/REV1 |
WP1 - CFA - OECD |
- |
- |
§ / 22-25 |
1st Revision of the Drafting improvements to the introduction,
title page, article 1, and article 3 of the model tax convention and the
commentaries thereon |
04/11/94 |
DAFFE/CFA/WP1/MR(94)17 |
WP1 - CFA - OECD |
- |
En |
III (4) / 5 |
Conflict of Qualifications; Discussion of the issues
(Preparing for the 1995 update) of the note DAFFE/CFA/WP1/MR(94)6/REV1 |
08/11/94 |
DAFFE/CFA/WP1/M(94)2 |
WP1 - CFA - OECD |
- |
En |
V / 5 |
Domestic law and meaning of undefined terms, definition of
national; discussion of the document DAFFE/CFA/WP1/MR(94)2/REV3 (The 1995
Update) |
08/11/94 |
DAFFE/CFA/WP1(94)9 |
WP1 - CFA - OECD |
- |
En |
§ / 4,12,14,35 |
The document contains the probable texts and reservations of
the 1995 Update and additional items that have not been formally agreed |
23/08/95 |
DAFFE/CFA/WP1/WD(95)17 |
WP1 - CFA - OECD |
- |
En |
12-16 / 3 |
Changes to the OECD model tax convention and its commentaries
from 1977-1995 |
12/09/95 |
DAFFE/CFA/WP1/MR(95)2/REV3 |
WP1 - CFA - OECD |
- |
En! |
IID / 8 |
Preparing for the 1995+update; International consensus on the
meaning of undefined terms |
19/12/95 |
DAFFE/CFA(95)16 |
CFA - OECD |
- |
- |
§ / 4 |
1995 changes to the OECD Model Convention and changes to the
observation and reservation |
20/12/95 |
DAFFE/CFA/WP1(95)5/REV3 |
WP1 - CFA - OECD |
- |
En |
IH / 6,7 |
Meaning of "enterprise", International consensus on
the meaning of undefined terms; Interaction between Articles 7 and 21;
Working party proposals for the 1995+ update to the model tax convention |
14/01/96 |
DAFFE/CFA/WP1(96)1 |
WP1 - CFA - OECD |
- |
En |
§ / 6 |
Comments of the BIAC on the Model Tax Convention to Working
Party 1 |
01/02/96 |
DAFFE/CFA/WP1/MR(96)3 |
WP1 - CFA - OECD |
- |
En |
9-12/ 3 |
Discussion of the Steering Group concerning the Definition of
international traffic |
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