| Date |
Document |
Institution |
MCC |
Or Lan |
§ / Pages |
Summary |
| 24/05/56 |
TFD/FC/2 |
FC - OEEC |
- |
- |
- |
List of the five Working Parties, of the subjects covered by
each of them and of the Member Countries composing each of them |
| 01/06/56 |
TFD/FC/5 |
WP1 - FC - OEEC |
DE, UK |
- |
- |
Proposal of the United Kingdom Delegate to the Draft Article
on Permanent Establishment |
| 06/06/56 |
TFD/FC/6 |
WP1 - FC - OEEC |
DE, UK |
- |
- |
Proposal of the French Delegation to the Draft Article on
Permanent Establishment |
| 06/06/56 |
TFD/FC/7 |
WP1 - FC - OEEC |
DE, UK |
- |
- |
Proposal of the British and German Delegations to the Draft
Article on Permanent Establishment |
| 17/09/56 |
FC/WP1(56)1 |
WP1 - FC - OEEC |
DE, UK |
En |
- |
Report on the concept of PE, Draft Article and its Commentary |
| 08/12/56 |
FC/M(56)2prov |
WP1 - FC - OEEC |
- |
Fr & En |
III/ 3 - 4 |
Comments on the report submitted by WP1 on the concept of PE
and proposed amendments to the Draft Article |
| 05/01/57 |
FC/WP1(57)1 |
WP1 - FC - OEEC |
DE, UK |
En |
- |
Revised Draft Article on the basis of the amendments decided
by the FCO at its meeting on 29th, 30th and 31st October 1956 |
| 24/01/57 |
TFD/FC/11 |
WP1 - FC - OEEC |
- |
En & Fr |
- |
Proposal of the Swiss Delegation to the Draft Article on
Permanent Establishment |
| 24/01/57 |
TFD/FC/11bis |
WP1 - FC - OEEC |
- |
En & Fr |
- |
Second version of the proposal of the Swiss Delegation to the
Draft Article on Permanent Establishment |
| 04/02/57 |
TFD/FC/12 |
WP1 - FC - OEEC |
DE, UK |
En & Fr |
- |
The WP asks the Delegates to give their views on the Draft
Article on Permanent Establishment (FC/WP1(57)1) |
| 08/02/57 |
FC/M(57)1 |
WP1 - FC - OEEC |
DE, UK |
Fr |
II/ 3 - 4 |
Comments and amendments to the Draft Article in the light of
the proposals received |
| 29/08/57 |
FC/WP1(57)2 |
WP1 - FC - OEEC |
DE, UK |
En |
- |
Revised report on the Concept of Permanent Establishemnt, with
a Draft Article and its Commentary |
| 02/10/57 |
TFD/FC/23 |
WP1 - FC - OEEC |
DE, UK |
Fr & En |
- |
New draft proposed for paragraph 3 (current 4) of the
Permanent Establishment article |
| 02/10/57 |
TFD/FC/25 |
WP1 - FC - OEEC |
DE, UK |
Fr & En |
- |
Final Drat Article on Permanent Establishment adopted by the
Committee |
| 02/10/57 |
TFD/FC/24 |
WP1 - FC - OEEC |
DE, UK |
Fr & En |
- |
Amendment of the Commentary following the removal of the term
"warehouse" from paragraph 2 |
| 05/11/57 |
FC/M(57)3 |
WP1 - FC - OEEC |
DE, UK |
Fr |
III/ 2 - 4 |
Comments by various Countries on the Report FC/WP1(57)2. Some
parts are illegible |
| 12/11/57 |
FC/WP1(57)3 |
WP1 - FC - OEEC |
DE, UK |
En |
- |
Report on the work of the WP, providing a Draft Article and
its Commentary |
| 06/01/58 |
FC/M(58)1 |
WP1 - FC - OEEC |
- |
Fr |
II/ 2 |
Discussion on whether to extend the list to
"laboratories" |
| 31/01/58 |
FC(58)1 |
WP1 - FC - OEEC |
DE, UK |
En |
- |
Final version of the Draft Article, with its Commentary, as
adopted by the Committee |
| 13/02/58 |
FC(58)2 |
WP1 - FC - OEEC |
- |
Fr |
- |
Report on the work of the Committee and the results achieved;
the text of the Article is provided in the annex, with an introductory
explanation before |
| 19/03/58 |
TFD/FC/32rev |
FC - OEEC |
- |
Fr & En |
III/ 4 |
Suggestions for the Drafting Group on how to draft the Model
and specific articles |
| 29/03/58 |
FC/M(58)2 |
FC - OEEC |
- |
Fr |
VIII/ 6 |
Approval with amendments of the Draft Article and its
Commentary in report FC(58)1 |
| 26/01/62 |
TFD/FC/137 (1st Revision) |
Drafting Group - FC - OECD |
- |
Fr & En |
§/10-11 |
Article text revised |
| 08/06/62 |
FC/M(62)3 |
FC - OECD |
- |
Fr |
IV / 9-10 |
Discussion on whether or not the combination of activities (a)
to (e) of then paragraph 3 [now Art. 5(4)] should be continue to fall within
the exception. |
| 26/07/62 |
FC/M(62)4 Part I |
FC - OECD |
- |
Fr |
V / 7 |
Debate about whether a combination of activities (a) to (e)
should or should not constitute a PE. UK proposes clause (f). Many member
states support. Committee to reconsider the UK text proposal. |
| 27/09/62 |
TFD/FC/149 |
FC - OECD |
UK |
- |
- |
Draft clause (f) of Article 5(3) of the Draft Model, as
proposed by the UK. |
| 06/11062 |
FC/M(62)5 |
FC - OECD |
UK US DE |
Fr |
V / 7-8 |
DE and US oppose the draft proposed by the UK and propose that
clause (f) should be accepted only if the combination of the activities is of
a preparatory or auxillary nature. |
| 13/02/63 |
FC/M(63)2 |
FC - OECD |
- |
Fr |
V / 4-5 |
No consensus over discussion whether, and to what extent
clause (f) should be excluded from the concept of a PE. Decided to let the
article be as it stood in the draft, and find a solution at a later date. |
| 21/02/63 |
FC(63)2 |
FC - OECD |
- |
En & Fr |
§ / 9 |
Latest draft model convention. |
| 22/05/63 |
TFD/FC/158 |
FC - OECD |
US |
En |
II / 3-4(App) |
US Criticism: (A) issues of time requirements for determining
permanence; (B) Excluded activities. |
| 22/05/63 |
TFD/FC/158 |
FC - OECD |
US |
En |
II / 5(App) |
US Criticism: (B) Excluded activities. |
| 22/05/63 |
TFD/FC/158 |
FC - OECD |
US |
En |
II / 6(App) |
US Criticism: (C) No clarity as to whether the exclusion does
not apply where the goods are purchased for delivery within the same
Contracting State. |
| 22/05/63 |
TFD/FC/158 |
FC - OECD |
US |
En |
II / 7(App) |
US Criticism: (D) interaction of excluded activities in 5(4)
and Article 8 not clear. |
| 22/05/63 |
TFD/FC/158 |
FC - OECD |
US |
En |
II / 8-9(App) |
US Criticism: (E) clarification needed as to when an
independent agent is to be considered to constitute a PE. |
| 22/05/63 |
TFD/FC/158 |
FC - OECD |
US |
En |
II / 10(App) |
US Criticism: (F) the word "company" used instead of
"enterprise" - preferable to use the term "enterprise". |
| 05/08/64 |
FC(64)1 |
FC - OECD |
JP |
En |
§1 / 2 |
Contends that activities under the provision include
supervision activities - under this interpretation, it has no reservations. |
| 08/09/64 |
TFD/FC/173 |
FC - OECD |
JP |
En |
§ / 4 |
Questions by the Japanese Delegation concerning the 1963 Draft
OECD Model. |
| 03/01/66 |
FC/WP25(66)2 |
WP25 - FC - OECD |
DK SE UK |
En |
- |
The Working Party recommended that the exception clause should
be liberally interpreted to exclude all combinations of listed activities -
and that the provision be amended to clarify so. |
| 11/05/66 |
TFD/FC/193 |
FC - OECD |
FR IE |
En & Fr |
- |
WP, Irish, and French proposals to amend clause (f) of the
exclusion provision: The Irish and French proposals entail deleting the word
“solely” in (a), (b), (c), (d) and (e). |
| 31/05/66 |
TFD/FC/196 |
FC - OECD |
- |
En |
§1 / 2 |
List of proposed amendments to the exclusion clause of Article
5. |
| 31/05/66 |
TFD/FC/196 |
FC - OECD |
- |
En |
§2 / 3-4 |
Discussion on what the scope of any amendment should be, and
the interrelationship between various paragraphs of Article 5. |
| 31/05/66 |
TFD/FC/196 |
FC - OECD |
- |
En |
§3 / 4 |
Discussion on whether any amendment should be made to the text
of the Article or the Commentary. |
| 14/11/66 |
TFD/FC/202 |
FC - OECD |
- |
En & Fr |
B / 3 |
Questions rainsed by Japan: reference: FC/WP25(66)2;
FC/WP25(66)1, §50–53; FC/M(66)1 page
5; FC/M(66)2 page 3; TFD/FC/196;
FC/M(66)3 page 4; WP in charge: WP7. |
| 06/02/67 |
TFD/FC/208 |
FC - OECD |
- |
En |
§ / 15-17 |
Analysis of conformity with or deviation from 1963 Draft OECD
Model in tax treaties signed between July 1963 and July 1966. |
| 27/02/67 |
TFD/FC/208 (ANNEX) |
FC - OECD |
- |
En |
§ / 4 |
Analysis of conformity with or deviation from 1963 Draft OECD
Model in tax treaties protocols signed between July 1963 and July 1966. |
| 28/02/67 |
TFD/FC/209 |
FC - OECD |
NO UK |
- |
§ / 7 |
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 |
Outstanding problems concerning articles 4 of the 1963 OECD
Draft Convention. |
| 13/03/67 |
TFD/FC/210 |
FC - OECD |
- |
En & Fr |
B / 4 |
Outstanding problems of drafting in the 1963 OECD Draft
Convention. |
| 09/05/67 |
TFD/FC/216 |
FC - OECD |
NO UK BE |
En & Fr |
§ / 7 |
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 UK BE GR DE |
En & Fr |
§ / 12-19 |
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 |
DE UK |
En & Fr |
§ / 7 |
Existing WP1 comprising DE & UK working on extended
mandate for Article 5. |
| 16/09/67 |
TFD/FC/222 |
FC - OECD |
- |
En |
§ / 22-25 |
Analysis of conformity with or deviation from 1963 Draft OECD
Model in tax treaties signed between 01/07/63 and 01/01/67. |
| 16/09/67 |
TFD/FC/222 |
FC - OECD |
- |
En |
§ / 109 |
Analysis of conformity with or deviation from 1963 Draft OECD
Model in protocols signed between 01/07/63 and 01/01/67. |
| 18/06/68 |
TFD/FC/231 |
FC - OECD |
- |
En! |
§ / 8-12 |
Analysis of conformity with or deviation from the 1963 OECD
Draft Convention in tax treaties between OECD and developing countries. |
| 21/10/68 |
FC(68)1 |
FC - OECD |
- |
En |
11-17 / 8-12 |
Analysis of deviations of actual tax treaties between OECD and
developing countries from July 1963 to July 1967. Includes observations made
by member states on TFD/FC/231 dt
14/06/68. |
| 16/05/69 |
DAF/FC/69.8 |
FC - OECD |
- |
En |
32-41/30-35 |
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. |
| 16/05/69 |
DAF/FC/69.8 |
FC - OECD |
- |
En |
205-206/164 |
Preliminary analysis of devaitions from the 1963 Draft in
protocols signed between 01/07/63 and 01/01/69 - supercedes TFD/FC/222 of
16/09/67. |
| 04/06/70 |
FC(70)1 |
FC - OECD |
- |
En |
32-41 / 25-29 |
Analysis of deviations of actual tax treaties concluded
amongst member countries, between 01/07/63 and 01/01/69 from the 1963 OECD
Draft. |
| 04/06/70 |
FC(70)1 |
FC - OECD |
- |
En |
205-206 / 127 |
Analysis of deviations of protocols concluded amongst member
countries, between 01/07/63 and 01/01/69 from the 1963 OECD Draft. |
| 17/08/70 |
FC/WP1(70)1 |
WP1 - FC - OECD |
DE UK |
En |
- |
Preliminary report on the questions in connection with the
definition of the term "Permanent Establishment". |
| 03/09/70 |
FC/WP7(70)1 (Corr) |
WP1 - FC - OECD |
DE UK |
En |
- |
Corrigendum to FC/WP7(70)1 dt 17/08/70. |
| 28/04/71 |
CFA(71)3 |
CFA - OECD |
- |
En |
- |
Organisation of work under the CFA: Work in early stages. Will
probably not be completed before mid-1972. |
| 07/06/71 |
CFA/WP1/A(71)1 |
WP1 - CFA - OECD |
- |
En & Fr |
IV / 1 |
Agenda: Continuation of discussion of the Report by Working
Group No 1 contained in FC/WP1(70)1 dt 17/08/70. |
| 23/09/71 |
DAF/CFA/WP1/71.5 |
WP1 - CFA - OECD |
- |
En |
III / 1 |
WP continued its first reading of the report of WG1
[FC/WP1(70)1 dt 17/08/70] and agreed to try to conclude it at its next
meeting. |
| 19/11/71 |
DAF/CFA/WP1/71.8 |
WP1 - CFA - OECD |
|
Fr |
II / 5-9 |
Examination of the Preliminary Report of WG1 [DE & UK] on
PEs, contained in [FC/WP1(70)1 of 17/08/70] |
| 04/02/72 |
DAF/CFA/WP1/72.2 |
WP1 - CFA - OECD |
- |
En |
II / 1-2 |
Australia objects to time criteria for PEs as it has
traditionally regarded fixedness to imply a geographically fixed character. |
| 14/02/72 |
DAF/CFA/WP1/72/3 |
WP1 - CFA - OECD |
- |
Fr |
I / 1-3 |
Continued examination of the Preliminary Report of WG1 [DE
& UK] on PEs, contained in [FC/WP1(70)1 of 17th August, 1970]. |
| 17/04/72 |
DAF/CFA/WP1/72.6 |
WP1 - CFA - OECD |
- |
Fr |
I / 1-3 |
Continued examination of the Preliminary Report of WG1 [DE
& UK] on PEs, contained in [FC/WP1(70)1 of 17th August, 1970]. |
| 18/05/73 |
DAF/CFA/2697 |
WP1 - CFA - OECD |
DE UK |
En |
- |
Potential amendments to the Article 5 and Commentary |
| 07/09/73 |
DAF/CFA/73.1 |
WP1 - CFA - OECD |
- |
En |
- |
Amendments to the commentary on article 5 of the OECD draft
convention |
| 11/06/74 |
DAF/CFA/WP1/74.10 |
WP1 - CFA - OECD |
- |
- |
1-9 / 2-7 |
The document discusses the he different potential principles
for the taxation of oilrigs And the proposed 12-month-time limit to
constitute a PE |
| 22/07/74 |
DAF/CFA/WP1/74.12 |
WP1 - CFA - OECD |
- |
En |
4 / 1 |
The relief of double taxation in high-sea drilling (oil rings)
dealing with paragraph 2f of Article 5 |
| 30/08/74 |
CFA/WP1(74)6 |
WP1 - CFA - OECD |
DE UK |
En |
- |
The report contains the proposed revised texts of the Article
and the Commentary, submitted to the Working Party N° 1 FOR CONSIDERATION. |
| 21/11/74 |
DAF/CFA/WP1/74.18 |
WP1 - CFA - OECD |
- |
- |
- |
Countries Opinion for the taxation of oilrigs; the Working
Party agreed that it was premature at this stage to seek solutions the
problem in the framework of Article 5 |
| 02/12/74 |
CFA/WP1(74)6 (Corr) |
WP1 - CFA - OECD |
DE UK |
En & Fr |
- |
Amendments to the document CFA/WP1(74)6 |
| 10/01/75 |
DAF/CFA/WP1/75.1 |
WP1 - CFA - OECD |
- |
Fr |
- |
The Working Party considered the[CFA/WP1(74)6 of 30th August,
1974] and agreed to examine it further at the next meeting. |
| 29/01/75 |
DAF/CFA/WP1/75.2 |
WP1 - CFA - OECD |
- |
Fr |
1 / 1 |
Amendments to the article and examination of the revised
report of Working Group No 1 -CFA/WP1/74.6 of 30th August, 1974] |
| 06/02/75 |
DAF/CFA/WP1/75.3 |
WP1 - CFA - OECD |
CH |
En & Fr |
- |
Observations prepared
by the Delegate for Switzerland concerning article 5 and. |
| 26/02/75 |
DAF/CFA/WP1/75.8 |
WP1 - CFA - OECD |
- |
Fr |
- |
[Examination of the revised report of Working Group No 1 -
CFA/WP1(74)6 of 30th August, 1974] |
| 13/03/75 |
DAF/CFA/WP1/75.7 |
WP1 - CFA - OECD |
- |
Fr |
4 / 1 |
The Working Party continued its examination of the report by
Working Group No. 1 [CFA/WP1(74)6 of 30th August, 1974] and would finish this
task at its next meeting. |
| 17/06/75 |
DAF/CFA/WP1/75.10 |
WP1 - CFA - OECD |
- |
Fr |
3 / 1 |
The Rapporteur would draft new texts of the document
[CFA/WP1(74)6 of 30th August, 1974] to be discussed by the Working Party in
the Autumn. |
| 21/07/75 |
DAF/CFA/WP1/75.11 |
WP1 - CFA - OECD |
- |
- |
2 / 2-6 |
[Examination by Working Group N° 1 - CFA/WP1(74)6 of 30th
August, 1974]. |
| 13/10/75 |
CFA/WP1(75)6 |
WG1 - WP1 - CFA - OECD |
DE UK |
En |
- |
The Report by WG1 on Article 5 on Permanent Establishment of
the 1963 Draft Convention and the Commentary thereon for consideration by WP1 |
| 22/12/75 |
DAF/CFA/WP1/75.15 |
WP1 - CFA - OECD |
- |
Fr |
1 / 1 |
The Working Party examined the Report by Working Group No 1
[CFA/WP1(75)6 of 13th October, 1975] and would continue to study it at the
next meeting. |
| 08/01/76 |
DAF/CFA/WP1/76.1 |
CFA - OECD |
- |
Fr |
- |
Amendments of the article and commentary, examination of the
Third Report by Working Group No. 1 -CFA/WP1(75)6 of 13th October, 1975 |
| 26/01/76 |
CFA/M(77)1 |
CFA - OECD |
- |
En |
3 / 2 |
Decitions taken concerning the 1963 draft double taxation
convention [CFA(76)7 parts I to IV) |
| 07/04/76 |
CFA/WP1(76)6 |
WG1 - WP1 - CFA - OECD |
DE UK |
- |
- |
The Revised texts by working Group N° 1 on Article 5 of the 1963 Draft Convention and the
Commentary thereon |
| 05/11/76 |
DAF/CFA/WP1/76.19 |
WP1 - CFA - OECD |
- |
En & Fr |
§ / 14 |
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 |
- |
- |
§ / 14 |
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 |
- |
- |
§ / 6 |
Part 4: Reservations on the Articles |
| 01/03/77 |
CFA (76)7part2rev1 |
WP1 - CFA - OECD |
- |
Fr & En |
§ / 14 |
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 |
§ / 4 |
1st revision and final version of Part 4 of the document
CFA(76)7: Reservations on the Articles |
| 28/09/77 |
DAF/CFA/WP1/77.11 |
CFA - OECD |
- |
En |
5 / 3 |
This report contains an analysis of the relationship between
the OECD Draft and bilateral Convention signed between seven OECD member
countries developing countries during the period July 1967 to November
1976. |
| 28/09/77 |
DAF/CFA/WP1/77.11 |
CFA - OECD |
- |
En |
§ / 10 |
This report contains an analysis of the relationship between
the OECD Draft and bilateral Convention signed between seven OECD member
countries developing countries during the period July 1967 to November
1976. |
| 07/10/77 |
DAF/CFA/WP1/77.12 |
WP1 - CFA - OECD |
US |
En |
5 / 8 |
The document contains the main differences between the OECD
and the United States Model Convention |
| 30/12/77 |
CFA/WP1(71) 6 |
WG23 - WP1 - CFA - OECD |
DE BE |
Fr |
- |
Final report part I that seeks a solution to the double
taxation of dividends in the case of Member countries whose law created
difficulties |
| 26/05/78 |
DAF/CFA/WP8/78.21 |
WP8 - CFA - OECD |
- |
Fr |
- |
Plan of work (France) for how to deal with itinerant
activities, which do not require fixed bases or PEs. |
| 14/03/79 |
DAF/CFA/WP8/79.7 |
WG1 - WP8 - CFA - OECD |
- |
- |
- |
Report of WG8 on issues concerning activities not requiring a
fixed base or PE. |
| 05/10/79 |
DAF/CFA/WP8/79.26 |
WP1 - CFA - OECD |
- |
En |
- |
Report dealing with the difficulties of taxing activities non
necessitating of a permanent basis |
| 10/09/81 |
DAF/CFA/WP1/81.11 |
WP1 - CFA - OECD |
- |
En |
- |
Preliminary paper on the problems connected with the taxation
of leasing of industrial, commercial or scientific equipment |
| 28/09/81 |
DAF/CFA/WP1/81.12 |
WP1 - CFA - OECD |
- |
En |
- |
Note on the problems with the taxation of container leasing |
| 14/12/81 |
DAF/CFA/WP1/81.14 |
WP1 - CFA - OECD |
- |
Fr |
IV/ 2 |
Comments on reports DAF/CFA/WP1/81.12 and DAF/CFA/WP1/81.11 on
the taxation of leasing and industrial, commercial and scientific equipment |
| 15/12/81 |
DAF/CFA/WP1/81.13 |
WP1 - CFA - OECD |
DE |
En |
- |
Extensive report from the German Delegation on the taxation of
income from the leasing of containers |
| 08/06/83 |
DAFFE/CFA/WP1/83.9 |
WP1 - CFA - OECD |
- |
Fr |
II.C / 1-2 |
Note on the 35th Meeting of WP1: WP examined report of the
Delegate of the UK [DAFFE/CFA/WP1/82.7] about the abuse of the 12-month
threshold of Article 5(3). |
| 14/11/83 |
C/83/102 (Final) |
CFA - OECD |
- |
- |
- |
Recommendation of the Council on the interpretation of
articles 5, 7 and 12 when applied to the taxation of income from the lease of
industrial, commercial or scientific equipment |
| 15/09/86 |
DAFFE/CFA/WP1/86.8 |
WP1 - CFA - OECD |
- |
En |
1 / 5, 3 / 14, App / 34 |
BIAC's report on the tax problems arising with softwares;
BIAC's review of tax issues related to specific articles of the 1977 OECD MC |
| 08/01/87 |
DAFFE/CFA/86.25 |
CFA - OECD |
- |
En |
1 / 2, 3 / 10 |
BIAC's review of tax issues related to specific articles of
the 1977 OECD MC; the document is submittee to the CFA for information |
| 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 |
§ / 7,8,9 |
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/WP1/89.3rev3 |
WP1 - CFA - OECD |
- |
En |
§ / 7,8,9 |
3rd Revision of the Observations and Reservations of the 1977
Model Convention; Answers received from the letter CFA(88)254 of 3rd October
1988. |
| 18/06/90 |
DAFFE/CFA/WP1/89.3rev3 (Corr) |
WP1 - CFA - OECD |
- |
En |
- |
Corrections to the document DAFFE/CFA/WP1/89.3 (3rd Revision) |
| 26/04/91 |
DAFFE/CFA/WP1/M(91)1 |
WP1 - CFA - OECD |
- |
En |
VI / 5 |
Revision of the 1977 Model; The leasing of Industrial,
Commercial and Scientific Equipment and Leasing of Containers was approved
subject to changes in the commentary |
| 11/10/91 |
DAFFE/CFA/WP1/M(91)2 |
WP1 - CFA - OECD |
- |
En |
VIII / 6 |
Clarification of the French and English version of paragraph
24 of the commentary. |
| 04/03/93 |
DAFFE/CFA/WP1/M(93)1 |
WP1 - CFA - OECD |
- |
En |
VI / 4,5,6 |
Amendments to the commentary of the article |
| 09/11/93 |
DAFFE/CFA/WP1/M(93)2 |
WP1 - CFA - OECD |
- |
En |
VII / 6 |
The revision of the Tax model Convention, Changes to the
commentary |
| 07/09/94 |
DAFFE/CFA/WP1/MR(94)8 |
WP1 - CFA - OECD |
- |
En |
§ / 2.3 |
The document contains the amendments to the observations and
reservations for inclusion in the 1995 update to the model tax
convention |
| 08/11/94 |
DAFFE/CFA/WP1(94)9 |
WP1 - CFA - OECD |
- |
En |
§ / 15,36 |
The document contains the probable texts and reservations of
the 1995 Update and additional items that have not been formally agreed |
| 15/02/95 |
DAFFE/CFA/WP1(95)5 |
WP1 - CFA - OECD |
- |
En |
§ / 3 |
Preparing for the 1996 Update; Recommendations of the Steering
Group |
| 23/08/95 |
DAFFE/CFA/WP1/WD(95)17 |
WP1 - CFA - OECD |
- |
En |
20-23,94 / 4,10 |
Changes to the OECD model tax convention and its commentaries
from 1977-1995 and Current issues being considered by working party |
| 02/10/95 |
DAFFE/CFA/WP1/WD(95)13/REV2 |
WP1 - CFA - OECD |
- |
En |
- |
Issues arising under article 5 (permanent establishment) of
the model tax convention |
| 19/12/95 |
DAFFE/CFA(95)16 |
CFA - OECD |
- |
- |
§ / 19 |
1995 changes to the OECD Model Convention and changes to the
observation and reservation |
| 14/01/96 |
DAFFE/CFA/WP1(96)1 |
WP1 - CFA - OECD |
- |
En |
§ / 7 |
Comments of the BIAC on the Model Tax Convention to Working
Party 1 |
| 05/02/96 |
DAFFE/CFA/WP1(96)5 |
WP1 - CFA - OECD |
- |
En |
3,10 / 2,3 |
Next update to the Model Tax Convention: possible contents,
changes to the commentary, changes to reservations and proposed timetable |
| 26/08/96 |
DAFFE/CFA/WP1(96)17 |
WP1 - CFA - OECD |
- |
En |
IIIB,F / 16,20 |
Proposals for the next update to the model tax convention |
| 13/09/96 |
DAFFE/CFA/WP1/WD(96)2 |
WP1 - CFA - OECD |
- |
En! |
- |
Issues arising under article 5 (permanent establishment) of
the model tax convention;updated version of note DAFFE/CFA/WP1(95)5/REV2 |
| 13/09/96 |
DAFFE/CFA/WP1/WD(95)13/REV3 |
WP1 - CFA - OECD |
- |
En |
- |
3rd revision of the Issues arising under article 5 (permanent
establishment) of the model tax convention;updated version of note
DAFFE/CFA/WP1(95)5/REV2 |
| 04/11/96 |
DAFFE/CFA/WP1/M(96)2 |
WP1 - CFA - OECD |
- |
En |
VII / 5 |
Discussion of the WP1 concerning Permanent Establishments
document DAFFE/CFA/WP1/WD(96)13/REV3 |
| 10/06/97 |
DAFFE/CFA/WP1/WD(97)10 |
WP1 - CFA - OECD |
- |
En! |
- |
The document discusses the issues arising under article 5
(permanent establishments) of the Model Tax Convention |
| 22/08/97 |
DAFFE/CFA/WP1(97)14 |
WP1 - CFA - OECD |
- |
En |
III / 12 |
Goods and services not attributable to a permanent
establishment ; Proposals for the next update to the Model Tax
Convention |
| 22/12/97 |
DAFFE/CFA/WP1/WD(95)13/REV6 |
WP1 - CFA - OECD |
- |
En |
- |
6th revision of the issues arising under article 5 (permanent
establishment) of the model tax convention |
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