Date |
Document |
Institution |
MCC |
Or Lan |
§ / Pages |
Summary |
03/07/57 |
C(57)145 |
FC - OEEC |
- |
Fr |
II(12)/ 5 |
List of the new five Working Parties |
28/10/57 |
FC/WP9(57)1 |
WP9 - FC - OECC |
IT, AT |
Fr |
- |
Report containing a Draft Article, the explanatory notes and a
few similar clauses from at that time current tax agreements |
26/02/58 |
TFD/FC/33 |
WP9 - FC - OECC |
IT, AT |
Fr! |
- |
The WP9 asks for observations and suggestions to the other
members of the Committee |
29/03/58 |
FC/M(58)2 |
FC - OEEC |
- |
Fr |
II/ 2 |
Comments and amendments to the report FC/WP9(57)1 |
03/05/58 |
TFD/FC/36 |
WP9 - FC - OECC |
IT, AT |
Fr |
- |
Second report containing a Draft Article and explanatory notes |
03/09/58 |
FC/WP9(58)1 |
WP9 - FC - OECC |
IT, AT |
Fr |
- |
Second report of the WP9 on the taxation of income from
immovable property, previously circulated as TFD/FC/36, containing a Draft
Article and explanatory notes |
23/09/58 |
TFD/FC/42 |
FC - OEEC |
NL |
Fr |
- |
Proposal from the Dutch Delegation on the taxation of income
from immovable property of enterprises |
24/09/58 |
TFD/FC/44 |
WP9 - FC - OECC |
IT, AT |
Fr & En |
- |
New version of the Draft Article |
25/09/58 |
TFD/FC/44rev1 |
WP9 - FC - OECC |
IT, AT |
Fr & En |
- |
Revised Draft Article |
05/11/58 |
FC(58)6 |
FC - OEEC |
- |
Fr |
- |
Approved Draft Article and Commentary submitted for adoption |
16/12/58 |
FC/M(58)5 |
FC - OEEC |
- |
Fr |
VI/ 8 |
Adoption of the Draft Article |
11/04/59 |
TFD/FC/62 |
FC - OEEC |
- |
Fr |
- |
List of observations on the drafting of the Article |
11/04/59 |
TFD/FC/63 |
FC - OEEC |
- |
Fr & En |
- |
Text of the Article for harmonisation |
21/04/59 |
TFD/FC/63rev1 |
FC - OEEC |
- |
Fr |
- |
Text of the Article after revision by the Drafting Group |
21/05/59 |
FC(59)2 |
FC - OEEC |
- |
Fr |
- |
Text of the Article as inseted in the Report from the Drafting
Group to the Council submitted to the Committee for adoption |
11/06/59 |
TFD/FC/69 |
FC - OEEC |
- |
Fr & En |
- |
Final text of the Article, annex to Recommendation TFD/FC/66 |
26/01/62 |
TFD/FC/137 |
Drafting Group - FC - OECD |
- |
Fr & En |
§ / 12, 13 |
Article text revised. Paragraphs 2, 3 and 4 revised;
conflicting references to agricultural or forestry enterprises in paras 3 and
4 removed. |
21/02/63 |
FC(63)2 |
FC - OECD |
- |
En & Fr |
§ / 10 |
Latest draft model convention. |
22/05/63 |
TFD/FC/158 |
FC - OECD |
US |
En |
IV(A) / 4-5 |
US Criticism requiring further study - computation of income from immovable
property when no profits attributable to a PE. |
22/05/63 |
TFD/FC/158 |
FC - OECD |
US |
En |
VI / 16 |
The use of the word "professional services" in Art.
6(4) and 22, and not "independent personal services". Not clear if
and what the distinction is, and if the choice of wording is deliberate. |
08/09/64 |
TFD/FC/173 |
FC - OECD |
JP |
En |
§ / 5 |
Questions by the Japanese Delegation concerning the 1963 Draft
OECD Model. |
14/11/66 |
TFD/FC/202 |
FC - OECD |
- |
En & Fr |
B / 3 |
Questions rainsed by Japan: allocation of taxing rights on
farming; reference: FC/WP25(66)1, §54–62; FC/M(66)3 page 4; WP in charge: --. |
06/02/67 |
TFD/FC/208 |
FC - OECD |
- |
En |
§ / 18-19 |
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 |
§ / 5 |
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 |
- |
§ / 8 |
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 / 3 |
1. Should there be an international definition of “immovable
property” and if so, what ? 2. Should income from agricultural and forestry
enterprises be treated under Article 6 or Article 7 ? |
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 |
§ / 8 |
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 CA DE |
En & Fr |
§ / 20-21 |
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 |
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 |
§ / 26-27 |
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 |
§ / 110 |
Analysis of conformity with or deviation from 1963 Draft OECD
Model in protocols signed between 01/07/63 and 01/01/67. |
16/05/69 |
DAF/FC/69.8 |
FC - OECD |
- |
En |
42-50/36-39 |
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 |
207-209/165 |
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. |
27/06/69 |
FC/WP30(69)1 |
WP30 - FC - OECD |
AT CH |
En |
72-92 / 23-28 |
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 |
1-e / 4 |
Discussion of WP30's work on Articles 6 of the 1963 OECD Draft
contained in FC/WP30(69)1 dt 27/06/69: "income from agricultural and
forestry"; assets of agricultural establishments; ships boats and air
transport profits, discussed. |
04/06/70 |
FC(70)1 |
FC - OECD |
- |
En |
42-50 / 30-33 |
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 |
207-209 / 128 |
Analysis of deviations of protocols 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 commentaries on Article 6,
which were agreed to by the Fiscal Committee. |
17/06/71 |
CFA/WP1(71)3 |
WP1 - CFA - OECD |
- |
En & Fr |
§ / 4, 11-14 |
Latest version of Article and Commentaries. |
10/11/71 |
CFA(71)10 |
CFA - OECD |
- |
Fr & En |
§ / 4, 18-19 |
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 |
§ / 5, 16-17 |
Revised text of Article and Commentary as adopted by WP1
during its 2nd session. Contents of CFA(71)10 dt 10/11/71 revised. |
25/03/75 |
CFA/WP1(75)2 |
WG30 - WP1 - CFA - OECD |
AU,BE,CH |
En |
§ / 5-8 |
Examples and solutions of the
divergent interpretation of the Model-convention concerning the
taxation of partnerships. |
12/05/75 |
CFA(75)4 |
CFA - OECD |
- |
En |
- |
Discussion on the present position in international tax
practice of the taxation at source or at place of residence of portfolio
investment income accruing to non-resident |
21/07/75 |
DAF/CFA/WP1/75.11 |
WP1 - CFA - OECD |
|
- |
3 / 6 |
Examination of the second Report of Working Group N°. 30 -
CFA/WP1(75)2 of 25th March, 1975 |
28/07/75 |
CFA/WP1(75)4 |
WG30 - WP1 - CFA - OECD |
AU,BE,CH |
En |
42 / 9 |
Income received by the partner from the partnership; A Partner
receives rents for immovable property situated in the other Contracting State
which has been leased to a permanent establishment |
12/09/75 |
CFA/WP1(75)5 |
WG15 - WP1 - CFA - OECD |
NL,JP,IE,CH |
En & Fr |
7 / 2-3 |
(The Double residence
Problem and possible solutions) Unsolved problems of elimination of double
taxation a continuation of the document CFA/WP1(74)2 |
30/10/75 |
DAF/CFA/WP1/75.14 |
WP1 - CFA - OECD |
- |
Fr |
A / 1 |
The amendment of the article as proposed by the Second Report
of Working Group Examination of the Second Report of Working Group No. 15 -
CFA/WP1(75)5 of 12th September, 1975 |
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 |
§ / 28 |
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 |
- |
- |
§ / 18 |
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 |
- |
- |
§ / 8 |
Part 4: Reservations on the Articles |
01/03/77 |
CFA (76)7part2rev1 |
WP1 - CFA - OECD |
- |
Fr & En |
§ / 18 |
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 |
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 |
07/10/77 |
DAF/CFA/WP1/77.12 |
WP1 - CFA - OECD |
US |
En |
1 / 9 |
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 |
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 |
§ / 10 |
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 |
§ / 10 |
3rd Revision of the Observations and Reservations of the 1977
Model Convention; Answers received from the letter CFA(88)254 of 3rd October
1988. |
23/08/95 |
DAFFE/CFA/WP1/WD(95)17 |
WP1 - CFA - OECD |
- |
En |
24-25,95 / 4,11 |
Changes to the OECD model tax convention and its commentaries
from 1977-1995 and Current issues being considered by working party |
23/08/96 |
DAFFE/CFA/WP1/MR(96)8 |
WP1 - CFA - OECD |
- |
En! |
§ / 7 |
OECD Translation section proposed editorial modifications of
the english version of the commentaries of articles 4, 6, 7 and 8 of the
model tax convention |
12/02/97 |
DAFFE/CFA/WP1/MR(96)8/REV1 |
WP1 - CFA - OECD |
- |
En! |
§ / 3,7 |
Proposed editorial modifications of the english version of
articles 4, 6, 7 and 8 of the Model Tax Convention |
12/02/97 |
DAFFE/CFA/WP1/WD(97)5 |
WG5 - WP1 - CFA - OECD |
- |
En! |
- |
Changes that would have to be made to the Model Tax Convention
if Article 14 were eliminated |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|