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 |
02/10/56 |
FC/WP5(56)1 |
WP5 - FC - OEEC |
BE, SE |
Fr |
A/ 1-9, 12-13 |
Report concerning the issue of double taxation, an overview of
national legislations and existing agreements; the WP recommends Member
Countries to follow the principle of POEM when entering into double taxation
agreements |
13/11/56 |
TFD/FC/9 |
WP5 - FC - OEEC |
BE, SE |
- |
- |
View of the WP on the issues discussed by the FCO at its
meeting on 31st October 1956 |
08/12/56 |
FC/M(56)2prov |
WP5 - FC - OEEC |
- |
Fr & En |
V/ 5 |
Comments and questions on the report submitted by WP5
reagrding various topics |
06/05/57 |
FC/WP5(57)2 |
WP5 - FC - OEEC |
BE, SE |
Fr |
- |
Revised report containing a Draft Recommendation and a
Commentary on it |
05/06/57 |
TFD/FC/15 |
WP5 - FC - OEEC |
BE, SE |
Fr |
- |
New Draft paragraphs 1 and 3 |
06/06/57 |
TFD/FC/17 |
FC - OEEC |
DE |
Fr |
- |
Proposal by the German Delegation on the concept of Fiscal
Domicile |
03/07/57 |
C(57)145 |
FC - OEEC |
- |
Fr |
II(12)/ 5 |
List of the new five Working Parties |
03/07/57 |
FC/M(57)2 |
WP5 - FC - OEEC |
- |
Fr |
III/ 2 - 3 |
Amendments to the Draft Recommendation (FC/WP5(57)2) |
03/09/57 |
FC/WP6(57)1 |
WP6 - FC - OEEC |
FR, DE |
Fr |
- |
Proposed amendments to the Draft Recommendation (FC/WP5(57)2)
and discussion on the taxation of enterprises not exclusively engaged in
shipping or air transport |
27/11/57 |
TFD/FC/29 |
WP6 - WP5 - FC - OEEC |
BE, SE, FR, DE |
Fr |
- |
New Draft Article |
29/11/57 |
TFD/FC/WP5/WP6 |
WP6 - WP5 - FC - OEEC |
BE, SE, FR, DE |
Fr |
- |
Draft Article adopted by the Committee |
19/12/57 |
TFD/FC/29final |
WP6 - WP5 - FC - OEEC |
BE, SE, FR, DE |
Fr! |
- |
Final text of the Article (French only) |
06/01/58 |
FC/M(58)1 |
WP6 - WP5 - FC - OEEC |
- |
Fr |
V/ 6-7, Ann II/ 10 |
The Committee approves the Draft Article in report
FC/WP6(57)1, and reviews report TFD/FC/29 |
07/02/58 |
FC/WP5(58)1 |
WP6 - WP5 - FC - OEEC |
BE, SE, FR, DE |
Fr |
- |
Final version of the Draft Article, with its Commentary, as
adopted by the Committee |
13/02/58 |
FC(58)2 |
WP6 - WP5 - 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 |
29/03/58 |
FC/M(58)2 |
FC - OEEC |
- |
Fr |
IX/ 8 |
Review of report FC/WP5(58)1 and amendments to the Commentary |
16/06/58 |
FC/M(58)3 |
FC - OEEC |
- |
Fr |
III(A)/ 3 |
Discussion on the principles underlying the provision on the
basis of the issues raised by the Greek Delegation; waiting to find a common
agreement on the provision, the Committee deletes Annex IV (i.e. Art 8) from
Report FC(58)2(1st Revision) |
16/09/58 |
FC(58)4 |
FC - OEEC |
- |
Fr & En |
- |
Report containing a Draft Article and its Commentary |
19/09/58 |
FC(58)4 |
FC - OEEC |
GR |
En |
A/ 1 |
Extensive explanation by the Greek Delegation of why it cannot
accept the principle of taxation in the "place of effective
managament" |
31/10/58 |
FC/M(58)4 |
FC - OEEC |
- |
Fr |
II/ 4 |
Amendments to the Article in the light of the issues raised by
the Greek and Norwegian Delegations |
06/11/58 |
FC(58)5 |
FC - OEEC |
- |
Fr & En |
- |
Draft Article as approved and its Comemntary submitted for
adoption |
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 & En |
- |
Text of the Article after revision by the Drafting Group |
27/04/59 |
FC(58)5rev1 |
FC - OEEC |
- |
Fr & En |
- |
Text of the Article as proposed by the Drafting Group of the
Fiscal Committee. Included are the Commentary and the exception in favour of
Greece |
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 (1st Rev) |
Drafting Group - FC - OECD |
- |
Fr & En |
§/16-17 |
Article text revised |
21/02/63 |
FC(63)2 |
FC - OECD |
- |
En & Fr |
§ / 12 |
Latest draft model convention. |
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. |
08/09/64 |
TFD/FC/173 |
FC - OECD |
JP |
En |
§ / 5-6 |
Questions by the Japanese Delegation concerning the 1963 Draft
OECD Model. |
06/02/67 |
TFD/FC/208 |
FC - OECD |
- |
En |
§ / 24-26 |
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 |
CH |
- |
§ / 11 |
Observations of member countries about difficulties in the
1963 OECD Draft Convention on income and capital. |
14/04/67 |
TFD/FC/214 |
FC - OECD |
- |
En |
§ / 4-6 |
Analysis of deviations from the 1963 Draft OECD Convention in
tax treaties signed between 1 July 1963 and 1 Jan 1967. |
09/05/67 |
TFD/FC/216 |
FC - OECD |
CH UK |
En & Fr |
§ / 12 |
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 |
CH UK DE CA |
En & Fr |
§ / 26-27 |
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. |
16/09/67 |
TFD/FC/222 |
FC - OECD |
- |
En |
§ / 32-35 |
Analysis of conformity with or deviation from 1963 Draft OECD
Model in tax treaties signed between 01/07/63 and 01/01/67. |
18/06/68 |
TFD/FC/231 |
FC - OECD |
- |
En! |
§ / 15-17 |
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 |
23-29 / 15-17 |
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 |
62-72/46-52 |
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. |
29/12/69 |
DAF/FC/69.17 |
FC - OECD |
- |
En |
C / 8-10 |
Discussion of report of WP 29 [FC/WP29(69)1 dt 06/11/69] -
(missing from database) about Article 8 issues: 'POEM v. Residence'; 'place
of registration'; sale of air tickets; base companies and p/s. |
04/06/70 |
FC(70)1 |
FC - OECD |
- |
En |
62-72 / 39-42 |
Analysis of deviations of actual tax treaties 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 |
108-109 / 41 |
The interrelationship between Articles 5 and 8. |
05/03/71 |
DAF/FC/71.5 |
FC - OECD |
- |
Fr |
II / 5-7 |
Note on the discussions at the 38th session of the FC,
examining WP29's report contained in FC/WF29(71)1. |
28/04/71 |
CFA(71)3 |
CFA - OECD |
- |
En |
- |
Organisation of work under the CFA: Work will be completed
very shortly. |
24/05/71 |
DAF/FC/71.6 |
FC - OECD |
- |
- |
II / 4-7 |
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]. |
07/06/71 |
CFA/WP1/A(71)1 |
WP1 - CFA - OECD |
- |
En & Fr |
IV / 1 |
Agenda: Approval of amendments to Article 8 and its
Commentaries proposed by WG29, contained in CFA/WP1(71)2 (not yet
circulated). |
08/06/71 |
DAF/CFA/WP1(71)1 |
WP1 - CFA - OECD |
TR |
Fr |
- |
Turkey's position with regard to Article 8 of the 1963 OECD
Draft. |
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 |
§ / 4-8 |
Changes to the text and commentary of Article 8. |
10/11/71 |
CFA(71)10 |
CFA - OECD |
- |
Fr & En |
§ / 5, 19-24 |
Revised text of Article and Commentary as unanimously approved
by the Fiscal Committee or by Working Party N° 1. |
07/01/72 |
CFA(71)10 (Corr) |
CFA - OECD |
- |
En & Fr |
D / 6 |
Corrigendum to the revised commentaries to Article 13 as
contained in CFA(71)10 dt 10/11/71, in order to harmonise it with the revised
commentaries on Article 8. |
07/01/72 |
CFA(71)10 (Corr) |
CFA - OECD |
- |
En & Fr |
E / 6 |
Minor corrigendum to the Article 8 and revised commentaries
thereon as contained in CFA(71)10 dt 10/11/71. |
10/02/72 |
CFA(71)10 (1st Rev) |
CFA - OECD |
- |
En & Fr |
§ / 6, 17-22 |
Revised text of Article and Commentary as adopted by WP1
during its 2nd session. Contents of CFA(71)10 dt 10/11/71 revised. |
15/09/73 |
CFA/VP1(73)9 |
WG30 - WP1 - CFA - OECD |
- |
Fr |
15/ 5 |
Can partnerships as such enjoy the benefits of Article 8? |
28/02/74 |
CFA/WP1(74)2 |
WG15 - WP1 - CFA - OECD |
NL,JP,IE,CH |
En |
30-32/ 10 |
Relationship between Article 23 and Article 8 |
11/06/74 |
DAF/CFA/WP1/74.10 |
WP1 - CFA - OECD |
- |
- |
7/ 5 |
The taxation of oilrigs (the wording of Article 8 on shipping
income does not apply to profits from the operation of drilling rigs) |
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 |
12/09/75 |
CFA/WP1(75)5 |
WG15 - WP1 - CFA - OECD |
NL,JP,IE,CH |
En & Fr |
11-14 / 5 |
Relationship between Article 23 and Article 8 (“shall be
taxable only”) |
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 |
§ / 41 |
The revised texts of
the Commentaries on the thirty Articles of the 1963 Draft Convention |
08/11/76 |
DAF/CFA/76.24 |
CFA - OECD |
US |
- |
- |
U.S. Note on Taxation of International Shipping |
22/11/76 |
CFA (76)7 PART II |
WP1 - CFA - OECD |
- |
- |
§ / 22 |
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 |
- |
- |
§ / 10 |
Part 4: Reservations on the Articles |
01/03/77 |
CFA (76)part2rev1 |
WP1 - CFA - OECD |
- |
Fr & En |
§ / 22 |
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 / 5 |
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 |
§ / p6 |
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 |
6 / 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 |
Part II/ p25 |
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 |
3 / 11 |
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 |
- |
Taxation of income from international shipping, a summary of
the replies of the Questionnaire (DAF/CFA/77.2 (1st Revision) |
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 |
§ / 11 |
Examples and solutions of the
divergent interpretation of the Model-convention concerning the
taxation of partnerships. |
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 |
§ / 13,14 |
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 |
§ / 13,14 |
3rd Revision of the Observations and Reservations of the 1977
Model Convention; Answers received from the letter CFA(88)254 of 3rd October
1988. |
07/09/94 |
DAFFE/CFA/WP1/MR(94)8 |
WP1 - CFA - OECD |
- |
En |
§ / 3,4 |
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 |
§ / 16 |
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 |
29-30 / 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! |
IIA / 6 |
Preparing for the 1995+update; Drafting the Model in
Gender-Neutral Language |
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 |
IE / 5 |
Article 8: Ships v. Boats (; Working party proposals for the
1995+ update to the model tax convention |
23/08/96 |
DAFFE/CFA/WP1/MR(96)8 |
WP1 - CFA - OECD |
- |
En! |
p18.19 |
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 |
26/08/96 |
DAFFE/CFA/WP1(96)17 |
WP1 - CFA - OECD |
- |
En |
IIIG / 20 |
Proposals for the next update to the model tax convention |
12/02/97 |
DAFFE/CFA/WP1/MR(96)8/REV1 |
WP1 - CFA - OECD |
- |
En! |
§ / 4,18-19 |
Proposed editorial modifications of the english version of
articles 4, 6, 7 and 8 of the Model Tax Convention |
13/02/97 |
DAFFE/CFA/WP1/MR(96)3/REV1 |
WP1 - CFA - OECD |
- |
En |
- |
Discussion of WP1 concerning issues 133 to 135: income from
international air transport |
11/07/97 |
DAFFE/CFA/WP1/MR/M(97)1 |
WP1 - CFA - OECD |
- |
En |
IIIC / 4 |
Discussion of WP1 concerning Income from international
transport document DAFFE/CFA/WP1/MR(96)3/REV1 |
22/08/97 |
DAFFE/CFA/WP1(97)14 |
WP1 - CFA - OECD |
- |
En |
IIIC / 12 |
Meaning of "effective management” ; Proposals for the
next update to the Model Tax Convention |
25/08/97 |
DAFFE/CFA/WP1/MR(96)3/REV2 |
WP1 - CFA - OECD |
- |
En |
- |
2nd revision of the discussion of WP1 concerning issues
arising from income of international air transport. |
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