| 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 |
| 04/09/58 |
FC/WP7(58)1 |
WP7 - FC - OEEC |
UK, NL |
En |
- |
First report containing a general discussion of the topic, a
Draft Article and its Commentary |
| 31/10/58 |
FC/M(58)4 |
FC - OEEC |
- |
Fr |
VII/ 10 |
Review and discussion on Report FC/WP7(58)1 |
| 10/11/58 |
FC/WP7(58)2 |
WP7 - FC - OEEC |
UK, NL |
En |
- |
The WP7 provides an explanation for critical words in the text
and suggests possible amendments to be discussed |
| 16/11/58 |
TFD/FC/47 |
FC - OEEC |
PT |
- |
- |
Proposal by the Portuguese Delegation to adopt the force of
attraction rule in lieu of the attribution of profits to a PE |
| 16/12/58 |
FC/M(58)5 |
FC - OEEC |
- |
Fr |
II/ 4 |
Extensive discussion based on Reports FC/WP7(58)1 and
FC/WP7(58)2 |
| 09/03/59 |
FC/WP7(59)1 |
WP7 - FC - OEEC |
UK, NL |
En |
- |
Report containing clarifications to the previous ones, a Draft
Article and its Commentary |
| 15/05/59 |
FC/M(59)2 |
FC - OEEC |
- |
Fr |
VI/ 11 |
Examination and amendments to the Article in report
FC/WP7(59)1 |
| 29/05/59 |
FC/WP7(59)2 |
WP7 - FC - OEEC |
UK, NL |
En |
- |
Revised text of the Draft Article |
| 05/08/59 |
FC/M(59)3 |
FC - OEEC |
- |
Fr |
III/ 7 |
Examination of the report FC/WP7(59)2 |
| 22/09/59 |
TFD/FC/77 |
FC - OEEC |
DE |
Fr & En |
- |
The German Delegation proposes an alternative to the taxation
based on separate accounts |
| 22/09/59 |
TFD/FC/76 |
WP7 - FC - OEEC |
UK, NL |
Fr & En |
- |
Draft Article as adopted by the Committee |
| 20/10/59 |
FC/M(59)4 |
FC - OEEC |
- |
Fr |
VII/ 7 |
Comments and proposals on different topics, mainly: the scope
of the article and the methods to be used for the attribution of profits to
the PE |
| 18/01/60 |
FC/WP7(60)1 |
WP7 - FC - OEEC |
UK, NL |
En |
- |
Revised report with a Draft Article and its Commentary |
| 03/02/60 |
TFD/FC/84 |
WP7 - FC - OEEC |
UK, NL |
En & Fr |
- |
Note on the expression "profits" |
| 20/02/60 |
FC/M(60)1 |
FC - OEEC |
- |
Fr |
II/ 3 |
Comments and amendments to the Article and its Commmentry in
report FC/WP7(60)1 |
| 14/03/60 |
FC(60)1 |
FC - OEEC |
- |
Fr & En |
- |
Text of the Article with its Commenary as adopted by the
Committee |
| 25/05/60 |
FC(60)2 |
FC - OEEC |
- |
Fr |
- |
Text of the Article as drafted by the Drafting Group |
| 21/07/60 |
C(60)157 (Final) |
Council - OEEC |
- |
- |
- |
Final text of the Article |
| 08/01/62 |
FC/WP14(62)1 |
WP14 - FC - OECD |
AT SE |
En |
§/11-12 |
WP14, for the first time proposes a draft paragraph [~7(7),
7(4)]; commentary on the interpretation of the term "profits". |
| 26/01/62 |
TFD/FC/137 (1st Revision) |
FC - OECD |
- |
Fr & En |
§/14-15 |
Article text revised. No ~Art. 7(7) despite FC/WP14(62)1 dated
08/01/62. |
| 19/02/62 |
FC/M/(62)1 |
Drafting Group - FC - OECD |
- |
Fr |
II / 5 |
The Commentary should specify that in such a case it could be
held that there were 2 distinct enterprises and that the profits should be
taxed, in the state in which the PE existed, in accordance with Art. XV. |
| 11/04/62 |
FC/M(62)2 Part I |
FC - OECD |
- |
Fr |
III / 5-7 |
WP14's proposal [in FC/WP14(62)1] of including new paragraph
[~7(7), 7(4)] discussed. WP14 asked to redraft the provision and report to
the FC. |
| 16/04/62 |
FC/WP14(62)3 |
WP14 - FC - OECD |
AT SE |
En |
§ / 3-4 |
Page 2 not legible; WP14's report on the priority of rules:
includes draft MC provision [~7(4)/7(7)], and draft commentary. |
| 08/06/62 |
FC/M(62)3 |
FC - OECD |
- |
Fr |
V / 10 |
FC adopted the report of WP15 FC/WP14(62)3 dated 16/04/62 -
priority rule to be inserted in the article. |
| 21/02/63 |
FC(63)2 |
FC - OECD |
- |
En & Fr |
§ / 11 |
Latest draft model convention. |
| 22/05/63 |
TFD/FC/158 |
FC - OECD |
US |
En |
IV(A) / 4-5 |
Unresolved issues requiring further study listed by the US -
attribution and computation of income to a PE / Fixed Base. |
| 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 |
A / 2 |
Questions relating to the 1963 Draft Convention left for
future discussion by the FC: paragraph of 1963 Report in which question was
raised: 14 & 54; Working Party in charge: WP7 |
| 14/11/66 |
TFD/FC/202 |
FC - OECD |
- |
En & Fr |
B / 3 |
Questions rainsed by Japan: Possibility of triple taxation
concerning business profits; reference: C/WP25(66)1, §63–74; FC/M(66)3 page 4; WP in charge: --. |
| 06/02/67 |
TFD/FC/208 |
FC - OECD |
- |
En |
§ / 20-23 |
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 |
§ / 6 |
Analysis of conformity with or deviation from 1963 Draft OECD
Model in tax treaties protocols signed between July 1963 and July 1966. |
| 27/02/67 |
FC/WP7(67)1 |
WP7 - FC - OECD |
UK NL |
En |
- |
Report on the "apportionment" of profits to a PEs
and AEs. |
| 28/02/67 |
TFD/FC/209 |
FC - OECD |
NO CH AT PT |
- |
§ / 9-10 |
Observations of member countries about difficulties in the
1963 OECD Draft Convention on income and capital. |
| 06/03/67 |
FC/WP7(67)1 Annex |
WP7 - FC - OECD |
US (UK NL) |
En |
- |
Copy of the US Federal Register containing proposed rules
about the steps in connection with arm’s length price adjustments, which are
being under consideration in the US received by WP7. |
| 13/03/67 |
TFD/FC/210 |
FC - OECD |
- |
En & Fr |
A / 3 |
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. |
| 24/03/67 |
TFD/FC/211 |
FC - OECD |
- |
En |
I.b / 2-3 |
Discussions between members of the FC surrounding several
issues concerning Article 24 and its relationship with Article 7. |
| 09/05/67 |
TFD/FC/216 |
FC - OECD |
NO CH PT AT UK SE BE |
En & Fr |
§ / 9-11 |
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 |
DE CA FR NO CH PT AT UK SE BE |
En & Fr |
§ / 22-25 |
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. |
| 24/07/67 |
FC/WP7(67)2 |
WP7 - FC - OECD |
US (UK NL) |
En |
- |
Observations of the US Delegate on the Report of WP7 on the
apportionment of profits of permanent establishments and associated
enterprises [FC/WP7(67)1 of 27th February, 1967]. |
| 25/07/67 |
TFD/FC/219 |
FC - OECD |
UK NL |
En & Fr |
§ / 7 |
Existing WP7 comprising UK & NL working on extended
mandate for Article 7 for allocation of profits to PEs & Aes, including
allocation of profits from the continental shelf. |
| 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. |
| 16/09/67 |
TFD/FC/222 |
FC - OECD |
- |
En |
§ / 28-31 |
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 |
§ / 111 |
Analysis of conformity with or deviation from 1963 Draft OECD
Model in protocols signed between 01/07/63 and 01/01/67. |
| 19/09/67 |
TFD/FC/223 |
WP7 - FC - OECD |
US (UK NL) |
En |
- |
Addendum to the Observations of the U.S. Delegate circulated
in document FC/WP7(67)2 dt 24/07/67. |
| 06/10/67 |
TFD/FC/226 |
FC - OECD |
- |
En |
- |
Notes on the discussion about the allocation of profits to a
PE and AEs at the 27th Session of the Fiscal Committee held from 19/09/67 to
22/09/67. |
| 18/06/68 |
TFD/FC/231 |
FC - OECD |
- |
En! |
§ / 13-14 |
Analysis of conformity with or deviation from the 1963 OECD
Draft Convention in tax treaties between OECD and developing countries. |
| 16/09/68 |
FC/WP7(67)1 - Annex (Add) |
WP7 - FC - OECD |
US (UK NL) |
En |
- |
Final regulations issued by the U.S. Treasury Department
dealing with the allocation of income between related entities (Section 482
of the Internal Revenue Code) circulated at the request of the US Delegate. |
| 21/10/68 |
FC(68)1 |
FC - OECD |
- |
En |
18-21 / 13-14 |
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 |
50-61/40-45 |
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 |
210-214/165-166 |
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 |
51-61 / 34-38 |
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 |
210-213 / 128-129 |
Analysis of deviations of protocols concluded amongst member
countries, between 01/07/63 and 01/01/69 from the 1963 OECD Draft. |
| 19/06/70 |
FC/WP7(70)1 |
WP7 - FC - OECD |
UK NL |
En |
- |
Study of 2 factors: what are the relevant factors in
determining ALP; whether corresponding adjustments should be made? |
| 13/10/70 |
DAF/FC/70.11 |
FC - OECD |
- |
En |
B (14-17, 18) / 5 |
Notes on the discussion about the second report of WP7 -
adjustment of prices between Head Offices and PEs. |
| 12/11/70 |
FC/WP7(70)2 |
WP7 - FC - OECD |
UK NL |
En |
15-39 / 6-12 |
Report on corresponding adjustments; and related timing issues
concerning profits attributed to a PE. |
| 28/04/71 |
CFA(71)3 |
CFA - OECD |
- |
En |
- |
Organisation of work under the CFA: Work will probably not be
completed before 1972. |
| 23/09/71 |
DAF/CFA/WP1/71.5 |
WP1 - CFA - OECD |
- |
En |
VII / 2 |
WG7 invites notes from countries which have practical
experience in the field of applying the ALP. |
| 21/02/72 |
CFA/WP1(72)4 |
WG7 - WP1 - CFA - OECD |
UK NL |
- |
1-54 / 1-18 |
4th Report of WG7: list of proposals on Article 7. |
| 07/07/72 |
DAF/CFA/WP1/72.8 |
CFA - OECD |
- |
Fr |
IV / 4 |
Notes on the 5th meeting of WP1 of the CFA: WP1 commenced its
examination of the 4th report by WG7 [ contained in CFA/WP1(72)4 dt
21/02/72]. Examination to be completed at the next session. |
| 28/07/72 |
DAF/CFA/WP1/72.9 |
WP1 - CFA - OECD |
- |
Fr |
II / 15-16 |
Discussion of the 4th report of WG7 [contained in CFA/WP1(72)4
of 21/02/72]. |
| 11/12/72 |
DAF/CFA/WP1/72.11 |
WP1 - CFA - OECD |
- |
En |
II / 2 |
WP1 concluded its discussion of the 4th report of WG7
[contained in CFA/WP1(72)4 dt 21/02/72] |
| 15/12/72 |
DAF/CFA/WP1/72.12 |
WP1 - CFA - OECD |
- |
En |
I / 1-3 |
Summary of discussions during the 6th Meeting of the CFA:
Discussion of the 4th report of WG7 [CFA/WP1(72)4 dt 21/02/72]. |
| 01/03/73 |
DAF/CFA/2584 |
WP1 - CFA - OECD |
- |
Fr |
- |
Equal treatment of permanent establishments and resident
enterprises carrying on the same activities. |
| 30/05/73 |
DAF/CFA/2718 |
WG7 - WP1 - CFA - OECD |
NL,DE |
En |
- |
Revised version of the proposals by Working Group N° 7 on
Article 7 |
| 22/08/73 |
CFA/WP1(73)8 |
WG7 - WP1 - CFA - OECD |
NL,UK |
En |
- |
The revised version of the 4th Report of the Working Group
dealing with Article 7 (DAF/CFA/2718) |
| 15/09/73 |
CFA/VP1(73)9 |
WG30 - WP1 - CFA - OECD |
Fr |
15 / 5 |
Can partnerships as such enjoy the benefits of Article 7? |
| 05/10/73 |
DAF/CFA/WP1/73.12 & Add. |
WP1 - CFA - OECD |
- |
En |
1 / 2 |
The revised texts drawn up by Working Group No 7 and revised
by the Steering Group [CFA/WP1(73)8 of 22nd August, 1973] were adopted |
| 05/11/73 |
DAF/CFA/WP1(73)13 |
WP1 - CFA - OECD |
- |
En |
- |
Amendments of the revised 4th Report of Working Group N° 7
(CFA/WP1(73)8 of the 22nd August 1973)] |
| 12/11/73 |
CFA/WP1(73 )10 |
WP1 - CFA - OECD |
- |
En & Fr |
- |
Revised text of Articles 4, 7, 10, 16, 17, 19, 24 and 27 of
the Draft Convention and the Commentaries thereon |
| 19/12/73 |
CFA(73)15 |
WP1 - CFA - OECD |
- |
En & Fr |
- |
Revised text of Articles 4, 7, 10, 16, 17, 19, 21, 24 and 27
of the 1963 OECD Draft Convention and of the Commentaries thereon and the
proposed amendments to Articles 3, 11 and 12 |
| 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 |
| 11/06/74 |
DAF/CFA/WP1/74.10 |
WP1 - CFA - OECD |
- |
- |
7 / 5 |
The taxation of oilrigs |
| 21/05/75 |
CFA/WP1(75)3 |
WG21 - WP1 - CFA - OECD |
US,DK,DE |
En |
14 / 10 |
Improper use and abuse of tax conventions trough a permanent
establishment |
| 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 |
- |
Income received by the partner from the partnership; Special
remuneration received by the partner from the partnership for services
rendered (adequateness of remuneration and services presupposed) |
| 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 |
§ / 29 |
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 |
- |
- |
§ / 20 |
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 |
- |
- |
§ / 20 |
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 / 4 |
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 |
§ / 6 |
1st revision and final version of Part 4 of the document
CFA(76)7: Reservations on the Articles |
| 04/04/77 |
DAF/CFA/WP1/77.5 & Add. |
WP1 - CFA - OECD |
- |
Fr |
2-9/ 1-2 |
The document shows problems with non-Member countries and the
application of Article 7 |
| 24/05/77 |
DAF/CFA/WP1/77.6 |
WP1 - CFA - OECD |
- |
- |
4 / 2 |
The document discusses the document [DAF/CFA/WP1/77.5 of 4th
April, 1977] and the question raised by the French Delegation in its note
[DAF/CFA/WP1/77.5 of 4th April, 1977 |
| 24/05/77 |
DAF/CFA/WP1/77.6 |
WP1 - CFA - OECD |
- |
- |
Annex 5 / 5 |
The document discusses the document [DAF/CFA/WP1/77.5 of 4th
April, 1977] and the question raised by the French Delegation in its note
[DAF/CFA/WP1/77.5 of 4th April, 1977 |
| 28/09/77 |
DAF/CFA/WP1/77.11 |
CFA - OECD |
- |
En |
Part II / p19 |
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 |
2 / p9 |
The document contains the main differences between the OECD
and the United States Model Convention |
| 15/03/78 |
CFA(78)1 |
WG2 - WP8 - CFA - OECD |
- |
En |
c1 / p5 |
Taxation of income from
shipping activities attributable to a Permanent establishment |
| 26/05/78 |
DAF/CFA/WP8/78.21 |
WP8 - CFA - OECD |
- |
Fr |
- |
The document covers certain types of activities, not
necessitating a fixed base to perform them. |
| 21/08/78 |
CFA(78)1 (Corr) |
WG2 - WP8 - CFA - OECD |
- |
Fr |
- |
Corrections to the document CFA(78)1 concerning the taxation
of International Shipping |
| 25/03/75 |
CFA/WP1(75)2 |
WG30 - WP1 - CFA - OECD |
AU,BE,CH |
En |
§ / p11 |
Examples and solutions of the
divergent interpretation of the Model-convention concerning the
taxation of partnerships. |
| 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 |
| 26/10/79 |
DAF/CFA/WP6/79.3 |
WP6 - CFA - OECD |
UK |
En |
- |
Note by the UK Delegation on transfer pricing in the banking
sector |
| 09/06/80 |
DAF/CFA/WP6/80.9 |
WP6 - CFA - OECD |
- |
En |
- |
Questionnaire on taxation of multinational banking
enterprises |
| 04/06/81 |
DAF/CFA/WP1/81.8 |
WP1 - CFA - OECD |
- |
Fr |
III/ 2 |
The WP is asked to clarify the taxation of containers leasing;
further it recognises the need to clarify the relationship between articles 7
and 12 |
| 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 |
| 28/06/82 |
DAFFE/CFA/WP1/82.6 |
WP1 - CFA - OECD |
- |
Fr |
V/ 2 |
Taxation of the leasing of containers; of industrial,
commercial or scientific equipments: it is agreed that the rule in art 12 is
the overriding one |
| 26/08/82 |
DAFFE/CFA/WP6/82.2 |
WP6 - CFA - OECD |
- |
En |
- |
Extensive report on transfer pricing and attribution of
profits in the banking sector |
| 02/05/83 |
DAFFE/CFA/WP6/83.5 |
WP6 - CFA - OECD |
- |
En |
- |
WP6 requests to WP1 interpretation on article 7 for the
purposes of its work on the taxation of multinational banking enterprises |
| 08/06/83 |
DAFFE/CFA/WP1/83.9 |
WP1 - CFA - OECD |
- |
Fr |
IV / 3 |
Discussion on the taxation of multinational banking
enterprises |
| 12/07/83 |
DAFFE/CFA/WP6/83.5rev1 (Corr) |
WP6 - CFA - OECD |
- |
En & Fr |
- |
Corrections to document DAFFE/CFA/WP6/83.5 |
| 19/07/83 |
DAFFE/CFA/WP1/83.10 |
WP6 - CFA - OECD |
- |
Fr |
- |
Extensive note on the taxation of multinational banking
enterprises |
| 14/11/83 |
C/83/102 (Final) |
Council - 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 |
| 21/11/83 |
DAFFE/CFA/WP1/83.10rev1 Part I |
WP1 - CFA - OECD |
- |
Fr |
- |
Report by WP1 in response to the questions raised by WP6 in
report DAFFE/CFA/WP1/83.10 on the taxation of income of multinational banking
enterprises |
| 10/02/84 |
DAFFE/CFA/WP1/84.1 |
WP1 - CFA - OECD |
- |
En |
- |
Report by the German Delegation on the improper use of tax
treaties through "base companies" |
| 13/02/84 |
DAFFE/CFA/WP1/83.10rev1 Part II |
WP1 - CFA - OECD |
- |
Fr |
- |
Report on the possible application of paragraph 5 by analogy
to international banking enterprise |
| 29/05/84 |
DAFFE/CFA/84.3 |
WP1 - CFA - OECD |
- |
Fr |
- |
WP1 answers WP6's questions concerning the application of
article 7 to the taxation of multinational banking enterprise |
| 17/09/84 |
DAFFE/CFA/WP1/84.1rev1 |
WP1 - CFA - OECD |
- |
Fr |
- |
First revision to report DAFFE/CFA/WP1/84.1 |
| 12/02/85 |
DAFFE/CFA/WP1/84.1rev2 |
WP1 - CFA - OECD |
- |
En |
- |
Second revision revision to report DAFFE/CFA/WP1/84.1 |
| 09/04/85 |
DAFFE/CFA/WP6/85.5 |
WP6 - CFA - OECD |
- |
En |
- |
The WP is requested to make a systematic assessment of the
problems related to the taxation of permanent establishments in a
multinational context |
| 15/09/86 |
DAFFE/CFA/WP1/86.8 |
WP1 - CFA - OECD |
- |
En |
1 / 5, 17 / 4 |
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, 4 / 12 |
BIAC's review of tax issues related to specific articles of
the 1977 OECD MC; the document is submittee to the CFA for information |
| 23/02/87 |
DAFFE/CFA/WP1/87.8 |
WP1 - CFA - OECD |
- |
Fr |
- |
Note by the French delegate concerning tax issues relating to
softwares |
| 25/08/87 |
DAFFE/CFA/WP1/87.12 |
WP1 - CFA - OECD |
- |
En |
- |
Note on the tax issues related to the use of softwares |
| 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 |
§ / 11,12 |
2nd Revision of the Observations and Reservations of the 1977
Model Convention; Answers received from the letter CFA(88)254 of 3rd October
1988. |
| 30/01/90 |
CFA/M(91)1 |
CFA - OECD |
- |
En |
IV / 3 |
Discussion of the report[DAFFE/CFA(91)6]
and the 183 days rule |
| 22/03/90 |
DAFFE/CFA/WP1/89.3rev3 |
WP1 - CFA - OECD |
- |
En |
§ / 11,12 |
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) |
| 25/09/90 |
DAFFE/CFA/WP1/M(90)2 |
WP1 - CFA - OECD |
- |
En |
II / 1 |
The 183 Days Rule; discussion of the note
DAFFE/CFA/WP1/89.6(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 Containers was
approved subject to changes in the commentary |
| 26/04/91 |
DAFFE/CFA/WP1/M(91)1 |
WP1 - CFA - OECD |
- |
En |
VI / 6 |
Revision of the 1977 Model;
The treatment of Entertainers, Artistes and Sportsmen was approved
subject to changes in the commentary |
| 19/11/91 |
DAFFE/CFA/WP6(90)1/REV3 |
WP6 - CFA - OECD |
- |
Fr |
- |
The document contains the 3rd revision of the note of Attribution of Income to
Permanent Establishments |
| 06/01/92 |
DAFFE/CFA(92)7 |
CFA - OECD |
- |
Fr |
- |
The document contains a note submitted for approval of the
CFA; Attribution of Income to Permanent Establishments |
| 18/02/92 |
DAFFE/CFA/M(92)1 |
CFA - OECD |
- |
En |
VII / 5 |
The Committee noted the document DAFFE/CFA(92)7 and pass it to
WP1 for the modification of the commentary |
| 09/03/92 |
DAFFE/CFA/WP1/M(92)1 |
WP1 - CFA - OECD |
- |
En |
IV / 3 |
The WP decided to create a working group to evaluate the
proposed amendments of the commentary of the document
(DAFFE/CFA/WP1(92)1) |
| 15/12/92 |
DAFFE/CFA/WP1/M(92)2 |
WP1 - CFA - OECD |
- |
En |
IV / 3 |
Discussion of the Chairman note DAFFE/CFA/WP1(92)15 on
attribution of income to a PE;
amendments to Annex C of the
document [DAFFE/CFA/WP1(92)1] |
| 29/01/93 |
DAFFE/CFA/WP6/M(92)2 |
WP6 - CFA - OECD |
- |
En |
V / 3 |
Attribution of income to PEs; Discussion of the proposed
amendments of document [DAFFE/CFA/WP1(92)1]
and the proposals of the delegate of Canada, Switzerland and the
United Kingdom. |
| 04/03/93 |
DAFFE/CFA/WP1/M(93)1 |
WP1 - CFA - OECD |
- |
En |
V / 3,4 |
Subject to this minor correction, the Working Party approved
the note by the Working Group. DAFFE/CFA/WP1(92)15/REV3, |
| 16/03/93 |
DAFFE/CFA/WP6(90)1/REV4 |
WP6 - CFA - OECD |
- |
Fr |
|
The document contains the 4rd revision of the note concerning
the attribution of Income to Permanent Establishments |
| 05/07/93 |
DAFFE/CFA/M(93)2 |
CFA - OECD |
- |
En |
VI, 7 |
The Committee approved the documents DAFFE/CFA(93)10,
DAFFE/CFA(93)10/CORR1, DAFFE/CFA(93)10/ADD1, DAFFE/CFA(93)10/ADD2 of
attribution of income to PEs |
| 09/08/93 |
DAFFE/CFA/WP1(93)5 |
WP1 - CFA - OECD |
- |
En |
E/ 8 |
The application of the model tax convention to partnerships,
trusts and other non-corporate entities |
| 07/09/94 |
DAFFE/CFA/WP1/MR(94)8 |
WP1 - CFA - OECD |
- |
En |
§ / 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 |
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 |
26-28/ 4 |
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! |
IIB / 7 |
Preparing for the 1995+update; Interaction between Articles 7
and 21 |
| 19/12/95 |
DAFFE/CFA(95)16 |
CFA - OECD |
- |
- |
§ / 20,25 |
1995 changes to the OECD Model Convention , changes to the
observation and reservation and organizational changes |
| 20/12/95 |
DAFFE/CFA/WP1(95)5/REV3 |
WP1 - CFA - OECD |
- |
En |
IF / 6 |
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 |
§ / 7 |
Comments of the BIAC on the Model Tax Convention to Working
Party 1 |
| 23/08/96 |
DAFFE/CFA/WP1/MR(96)8 |
WP1 - CFA - OECD |
- |
En! |
§ / 3,4,7-18 |
OECD Translation section proposed editorial modifications of
the english version of articles 4, 6, 7 and 8 of the model tax
convention |
| 26/08/96 |
DAFFE/CFA/WP1(96)17 |
WP1 - CFA - OECD |
- |
En |
IIIF / 19 |
Proposals for the next update to the model tax convention |
| 12/02/97 |
DAFFE/CFA/WP1/MR(96)8/REV1 |
WP1 - CFA - OECD |
- |
En! |
§ / 3,4,7-18 |
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 |
| 22/08/97 |
DAFFE/CFA/WP1(97)14 |
WP1 - CFA - OECD |
- |
En |
IIIB / 11 |
Goods and services not attributable to a permanent
establishment ; Proposals for the next update to the Model Tax
Convention |
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