Date |
Document |
Institution |
MCC |
Or Lan |
§ / Pages |
Summary |
29/03/58 |
FC/M(58)2 |
FC - OEEC |
- |
Fr |
X/ 8 |
Creation of WP12 composed by Germany, Italy and Switzerland |
28/11/58 |
FC/WP12(58)1 Part II |
WP12 - FC - OECC |
DE, IT, CH |
Fr |
- |
Extensive report containing a general analysis and practical
solutions as found in historical documents and at that time current bilateral
conventions |
28/11/58 |
FC/WP12(58)1 Part I |
WP12 - FC - OECC |
DE, IT, CH |
Fr |
- |
Extensive report containing a general analysis, a Draft
Article (in different versions) and its Commentary |
19/01/59 |
TFD/FC/52 |
FC - OEEC |
IT |
Fr |
- |
Proposed amendment by the Italian Delegation |
16/02/59 |
TFD/FC/56 |
FC - OEEC |
- |
En |
- |
Suggestions from a US perspective on how to deal with the
contentious issue of the allocation of taxing rights |
28/02/59 |
FC/M(59)1 |
FC - OEEC |
- |
Fr |
II/ 4 |
Extensive discussion based on report FC/WP12(58)1 |
02/03/59 |
TFD/FC/57 |
WP12 - FC - OEEC |
DE, IT, CH |
Fr |
- |
Questionnaire to Member Countries on domestic taxation of
company profits and dividends; similar clauses from existing tax agreemenst
and suggestions are provided |
19/03/59 |
TFD/FC/57rev1 |
WP12 - FC - OEEC |
DE, IT, CH |
Fr |
- |
Revised questionnaire to Member Countries on domestic taxation
of company profits and dividends |
08/01/60 |
FC/WP12(60)1 |
WP12 - FC - OEEC |
DE, IT, CH |
Fr |
- |
Taxation of comapany profits and dividends in Member
Countries |
31/03/60 |
TFD/FC/88 |
WP12 - FC - OEEC |
DE, IT, CH |
Fr |
- |
Proposed amendments to report FC/WP12(60)1 |
31/03/60 |
TFD/FC/88rev1 |
WP12 - FC - OEEC |
DE, IT, CH |
Fr |
- |
Proposed amendments to report FC/WP12(60)1 |
28/04/60 |
FC/M(60)2 |
FC - OEEC |
- |
Fr |
II/ 3 |
Extensive discussion on the attribution of taxing rights in
the State of source in the light of report FC/WP12(60)1 |
30/04/60 |
FC/WP12(60)2 |
WP12 - FC - OEEC |
DE, IT, CH |
Fr |
- |
New Draft Article with its Commentary and questions for
discussion |
28/05/60 |
FC/M(60)3 |
FC - OEEC |
- |
Fr |
IV/ 10 |
Discussion on the questions raised in document FC/WP12(60)2 |
09/06/60 |
TFD/FC/98 |
WP12 - FC - OEEC |
DE, IT, CH |
Fr |
- |
Comparable table of proposals by the Working Parties |
01/08/60 |
FC/WP12(60)3 |
WP12 - FC - OEEC |
DE, IT, CH |
Fr |
- |
New Draft Article |
24/09/60 |
FC/WP12(60)4 |
WP12 - FC - OEEC |
DE, IT, CH |
Fr |
- |
Extensive report containing a Draft Article, its Commentary
and an overview of the taxation of company profits and dividends in Member
Countries |
12/10/60 |
FC/M(60)5 |
FC - OEEC |
- |
Fr |
V/ 5 |
Discussion on report FC/WP/12(60)3 with amendments to the
Article |
23/12/60 |
FC/M(60)6 |
FC - OEEC |
- |
Fr |
II/ 3 |
Discussion on report FC/WP12(60)4 |
06/01/61 |
FC/WP12(61)1 |
WP12 - FC - OEEC |
DE, IT, CH |
Fr |
- |
Revised report with a Draft Article and its Commentary |
09/01/61 |
FC/WP12(61)2 |
FC - OEEC |
BE |
Fr |
- |
Belgian position with regard to the problem of the double
taxation of dividends |
12/01/61 |
TFD/FC/104 |
FC - OEEC |
NL |
- |
- |
Note by the Dutch Delegation explaining its position on the
Article |
17/01/61 |
TFD/FC/106 |
FC - OEEC |
DE |
En |
- |
Proposed paragraph by the German Delegation to be inserted in
the Commentary |
18/01/61 |
TFD/FC/107 |
FC - OEEC |
NL, DE |
En |
- |
Proposal by the Dutch and German Delegations for a paragraph
to be inserted in the Commentary |
17/02/61 |
FC/M(61)1 |
FC - OEEC |
- |
Fr |
III/ 4 |
Discussion on report FC/WP12(61)1 and on the proposals
submitted by several Countries |
20/02/61 |
FC/WP12(61)3 |
WP12 - FC - OEEC |
DE, IT, CH |
Fr |
- |
Final report containing a Draft Article and its extensive
Commentary |
31/03/61 |
FC/M(61)2 |
FC - OEEC |
- |
Fr |
II/ 3 |
Discussion on report FC/WP12 (61)3 |
31/03/61 |
TFD/FC/116 |
FC - OEEC |
- |
Fr |
- |
Note collecting the various reservations on the Article |
10/04/61 |
TFD/FC/118 |
FC - OEEC |
DK, NO, SE |
- |
- |
Statement to clarify reservations |
04/05/61 |
TFD/FC/126 Annexes |
FC - OEEC |
- |
Fr & En |
- |
Text of the Article and its Commentary as drafted by the
Drafting Group of the FCO |
23/05/61 |
FC(61)1 Annexes |
FC - OEEC |
- |
Fr & En |
- |
Final text of the Article and its Commentary |
25/05/61 |
FC/M(61)3 |
FC - OEEC |
- |
Fr |
III/ 3 |
Various reservations |
08/06/61 |
TFD/FC/129 |
FC - OEEC |
- |
Fr & En |
- |
Amendments to the Commentary |
19/06/61 |
C(61)97 |
Council - OEEC |
- |
Fr |
- |
Text of the Article |
19/06/61 |
C(61)97 Annexes F to J |
Council - OEEC |
- |
Fr & En |
- |
Text of the Commentary |
26/01/62 |
TFD/FC/137 (1st Revision) |
Drafting Group - FC - OECD |
- |
Fr & En |
§/20-21 |
Article text revised |
21/02/63 |
FC(63)2 |
FC - OECD |
- |
En & Fr |
§ / 14 |
Latest draft model convention. |
22/05/63 |
TFD/FC/158 |
FC - OECD |
US |
En |
III / 11-12(App) |
US Criticism: it is critical to determine as precisely as
possible when an asset is sufficiently connected with a PE to be taxed under
the rules of Art. 7. Confusion arises because Arts. 13 and 22 allow the other
contracting state to tax when the asset "forms part of the assets of the
PE", and the commentary on Art. 10(3) allows taxation of dividends under
Art. 7 if: "holdings form part of assets of the PE, or otherwise effectively connected with that establishment. |
22/05/63 |
TFD/FC/158 |
FC - OECD |
US |
En |
IV / 13(App) |
US Criticism: (A) No indication as to what the word
"capital" means. This may cause difficulties given the variety of
meanings which may be given to the term under the laws of even a single
state. |
22/05/63 |
TFD/FC/158 |
FC - OECD |
US |
En |
IV / 13(App) |
US Criticism: (B) No reference to the time at which or the
period during which the 25% interest in capital must have been held in order
to make the limitation therein provided applicable. |
05/08/64 |
FC(64)1 |
FC - OECD |
JP |
En |
§3 / 2 |
Japan reserves its position on Art. 10(2)(a) because it
imposes the split rate system. |
14/11/66 |
TFD/FC/202 |
FC - OECD |
- |
En & Fr |
A / 2 |
Questions relating to Amplification of article on dividend in
the 1963 Draft Convention left for future discussion by the FC: paragraph of
1963 Report in which question was raised: 53; Working Party in charge: WP23 |
14/11/66 |
TFD/FC/202 |
FC - OECD |
- |
En & Fr |
A / 2 |
Questions relating to international definition of dividends in
the 1963 Draft Convention left for future discussion by the FC: paragraph of
1963 Report in which question was raised: 53; Working Party in charge: -. |
06/02/67 |
TFD/FC/208 |
FC - OECD |
- |
En |
§ / 29-33 |
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 |
§ / 7-9 |
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 |
PT |
- |
§ / 12 |
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 |
§ / 9-13 |
Analysis of deviations from the 1963 Draft OECD Convention in
tax treaties signed between 1 July 1963 and 1 Jan 1967. |
17/04/67 |
TFD/FC/214 (ANNEX) |
FC - OECD |
- |
En |
§ / 3-5 |
Analysis of deviations from the 1963 Draft OECD Convention in
tax treaties protocols signed between 1 July 1963 and 31 July1966. |
09/05/67 |
TFD/FC/216 |
FC - OECD |
PT UK BE |
En & Fr |
§ / 14-15 |
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 PT UK BE |
En & Fr |
§ / 29-32 |
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 |
BE DE |
En & Fr |
§ / 7 |
Existing WP23 comprising BE & DE working on extended
mandate for Article 10. |
16/09/67 |
TFD/FC/222 |
FC - OECD |
- |
En |
§ / 38-43 |
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 |
§ / 112-114 |
Analysis of conformity with or deviation from 1963 Draft OECD
Model in protocols signed between 01/07/63 and 01/01/67. |
26/02/68 |
TFD/FC/229 |
FC - OECD |
- |
En |
A / 1-4 |
Notes from the 28th session of the FC - scope of study
included how one may create rules for alleviating EDT - discussions and
comments. |
18/06/68 |
TFD/FC/231 |
FC - OECD |
- |
En! |
§ / 18-21 |
Analysis of conformity with or deviation from the 1963 OECD
Draft Convention in tax treaties between OECD and developing countries. |
17/09/68 |
TFD/FC/233 |
FC - OECD |
GR |
Fr |
- |
Memorandum presented by Mr. Demetre Georgilis, Director for
Direct Taxation of the Greek Ministry of Finance. |
21/10/68 |
FC(68)1 |
FC - OECD |
- |
En |
30-36/18-21 |
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. |
15/11/68 |
TFD/FC/234 |
FC - OECD |
- |
- |
- |
Notes from the 29th session of the FC about discussions on BE
report for WP23 on the taxtaion of dividends [FC/WP23(68)1 dt 10/06/68 -
missing from database] including Economic Double Taxation and relief methods. |
28/01/69 |
DAF/FC/69.3 |
FC - OECD |
GR |
Fr |
- |
Proposal by Mr. D. Georgilis, Director for Direct Taxation of
the Greek Ministry of Finance, about Article 10, and the avoidance of
economic and juridical double taxation. |
16/05/69 |
DAF/FC/69.8 |
FC - OECD |
- |
En |
79-91/56-63 |
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 |
215-224/166-170 |
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. |
20/10/69 |
DAF/FC/69.13 |
FC - OECD |
- |
En |
A / 1-6 |
Notes of the discussion about the (im)possibility of
formulating a precise rule for relieving economic double taxation through
Article 10. |
04/06/70 |
FC(70)1 |
FC - OECD |
- |
En |
79-91 / 46-52 |
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 |
215-224 / 129-133 |
Analysis of deviations of protocols concluded amongst member
countries, between 01/07/63 and 01/01/69 from the 1963 OECD Draft. |
05/03/71 |
DAF/FC/71.5 |
FC - OECD |
- |
Fr |
I / 1-4 |
Note on the discussions at the 38th session of the FC on the
taxation of dividends, examining the draft final report of WP23 contained in
FC/WP23(70)1 dt 08/12/70, and Addendum. |
07/06/71 |
CFA/WP1/A(71)1 |
WP1 - CFA - OECD |
- |
En & Fr |
IV / 1 |
Agenda: Discussion of the Addendum to the Final Report by WG23
[contained in FC/WP23(71)1 dt 29/04/71] on double taxation of dividends
received by an individual. |
23/09/71 |
DAF/CFA/WP1/71.5 |
WP1 - CFA - OECD |
- |
En |
II / 1 |
WP1 completed amendment discussions as per WG23's report
[FC/WP23(70)1 dt 08/12/70] and directed the secretariat to produce a
consolidated report; also agreed to amend Art. 10 (except paras. 1&2) as
per FC/WP23(71)1 dt 29/04/71, p. 18. |
19/11/71 |
DAF/CFA/WP1/71.8 |
WP1 - CFA - OECD |
- |
Fr |
I / 1-5 |
Examination of 3rd Report of WG23 [BE & DE] on Dividends
contained in [FC/WP23(70)1 of 8th December, 1970]. Amendments agreed to. |
03/12/71 |
DAF/CFA/71.1 |
WG33 - WP1 - CFA - OECD |
- |
- |
- |
Questionnaire concerned with the tax treatment accorded
investment institutions (i.e. companies, funds, unit trusts and other
entities, which spread investment risks) and with the tax treatment of their
investors. |
07/12/71 |
DAF/CFA/WP1/71.9 |
WP1 - CFA - OECD |
- |
En |
- |
Revised commentary on Article 10 with respect to dividends
paid to individuals of the 1963 OECD Draft. |
20/12/71 |
CFA/M(71)2 |
CFA - OECD |
- |
En |
II / 3 |
General discussion of the report of WP3 [CFA(71)6 dt 05/11/71
and Addendum of 10/11/71] adopted by the Fiscal Committee. |
30/12/71 |
CFA/WP1(71)6 |
WG23 - WP1 - CFA - OECD |
BE DE |
Fr |
- |
Part I of the Final Report on double taxation of dividends
received by an individual. |
11/01/72 |
DAF/CFA/WP1(72)2 |
WP1 - CFA - OECD |
- |
En! |
- |
WP1 approves the revised commentary contained in
DAF/CFA/WP1(71).9 dt 07/12/71 in respect of dividends paid to individuals. |
21/01/72 |
CFA/WP1(72)1 |
WG26 - WP1 - CFA - OECD |
US FR NL |
En |
- |
Report on methods (address/automatic or refund) used to reduce
tax at the source; discusses administrative procedures and issues. |
01/02/72 |
CFA/WP1(71)6 (Corr) |
WG23 - WP1 - CFA - OECD |
BE DE |
Fr |
- |
Corrigenda of Part 1 of the report on double taxation of
dividends paid to an individual contained in CFA/WP1(71)6 dt 30/12/71. |
02/02/72 |
CFA/WP1(72)3 |
WP1 - CFA - OECD |
- |
En |
- |
Revised text of Section IV of the Commentary on Article 10 of
the Draft Convention concerning Dividends, as agreed by WP1 on 14/01/72. |
04/02/72 |
DAF/CFA/WP1/72.2 |
WP1 - CFA - OECD |
- |
En |
IV / 2 |
WP1 approves the text of the revised commentary on Article 10
of the 1963 OECD Draft with respect to Individuals, as contained in
DAF/CFA/WP1/71.9 dt. 07/12/71. |
25/04/72 |
DAF/CFA/WP1/72.7 |
WG23 - WP1 - CFA - OECD |
BE DE |
En |
- |
Questionnaire on the taxation of dividends paid to companies
designed to bring up-to-date the information on dividend taxation systems of
OECD member countries. |
15/06/72 |
CFA(72)7 |
CFA - OECD |
- |
En |
29 / 8 |
Relevance of Article 10 for the taxation of internatioal
companies. |
14/05/73 |
CFA/WP1(23)73 |
WG23 - WP1 - CFA - OECD |
DE BE |
En |
- |
Revision of Article 10 and the commentary thereon. |
01/03/73 |
DAF/CFA/2584 |
WP1 - CFA - OECD |
- |
Fr |
§ / p4-9 |
(Non- Discrimination of
PE) Special treatment of dividends received in respect of holdings owned by
permanent establishment and Withholding tax on dividends, interest and
royalties received by a permanent establishment |
11/04/73 |
CFA/WP1(73)2 |
WP1 - CFA - OECD |
- |
Fr |
- |
Summary of the Document "CFA/WP1(73)1 1st Revision”
Regarding Article 10 of the 1963 Model |
11/04/73 |
DAF/CFA/WP1/73.5 |
WP1 - CFA - OECD |
- |
En |
- |
Discussion of the report of Working Group no 23 (CFA/WP1(73) |
15/09/73 |
CFA/VP1(73)9 |
WG30 - WP1 - CFA - OECD |
- |
Fr |
16 / 5 |
Can partnerships as such enjoy the benefits of Article 10? |
05/10/73 |
DAF/CFA/WP1/73.12 & Add. |
WP1 - CFA - OECD |
- |
En |
3 / 2 |
The revised texts drawn up by Working Working Group No 23 on
Article 10 [CFA/WP1(73)7 (1st Revision) of 23rd July, 1973] were adopted |
05/11/73 |
DAF/CFA/WP1(73)13 |
WP1 - CFA - OECD |
- |
En |
- |
Amendments of the 2nd Report of Working Group N° 23 on
CFA/WP(73)7 (1st Revision of 23rd July, 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 |
08/02/74 |
CFA/WP1(74)1 |
WG23 - WP1 - CFA - OECD |
DE,BE |
En |
- |
Analysis of the replies to the questionnaire on dividends
[DAF/CFA/WP1/72.7 of 25th April, 1972] |
22/03/74 |
DAF/CFA/WP1/74.7 |
WP1 - CFA - OECD |
- |
En & Fr |
- |
Table of Tax treatment of dividends under the double taxation conventions [see
DAF/CFA/WP1/73.13 of 5th October, 1973, item VI]. |
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 |
21/05/75 |
CFA/WP1(75)3 |
WG21 - WP1 - CFA - OECD |
US,DK,DE |
En |
14,22,30/ 10,16-18,26,27 |
Repratriation of Profits in form of Dividends, Dividends for
individuals and Improper use and abuse
of tax conventions |
08/07/75 |
CFA/M(75)2 |
CFA - OECD |
- |
En |
9 / 6 |
The proposal of the United States administration to abolish
withholding tax on interest and portfolio dividend income CFA(75)4 |
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 |
12-22 / 3-8 |
Income received by the partner from the partnership; Treatment
of the share of profits allotted by the partnership to the individual
partners |
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 |
- |
- |
§ / 48 |
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 |
- |
- |
§ / 26,28 |
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 |
- |
- |
§ / 14 |
Part 4: Reservations on the Articles |
01/03/77 |
CFA (76)7rev 1 Part I |
WP1 - CFA - OECD |
- |
Fr & En |
§ / 26,28 |
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 |
1 / 1 |
The document contains the amendments and observations made by
Member countries to the Commentaries |
04/03/77 |
CFA(76)7 Part III (Corr) |
WP1 - CFA - OECD |
- |
En & Fr |
2 / 6 |
The document observations made by Member countries to the
Commentary |
07/03/77 |
CFA(76)7rev 1 Part I |
WP1 - CFA - OECD |
- |
En & Fr |
- |
1st revision and final version of Part I CFA(76)7, Part I |
11/03/77 |
CFA(76)7rev 1 Part IV |
WP1 - CFA - OECD |
- |
En & Fr |
§ / 8 |
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 / 32 |
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 / 12 |
The document contains the main differences between the OECD
and the United States Model Convention |
09/12/77 |
CFA(77)12 |
CFA - OECD |
- |
En |
V/ 4,5 |
Discussion of national treatment in the international
investment treaties and multinational enterprises by the OECD |
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 |
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. |
08/06/83 |
DAFFE/CFA/WP1/83.9 |
WP1 - CFA - OECD |
- |
Fr |
C / 1-2 |
Discussion around the possibilities of abusing the 25%
threshold in Article 10(2)(a). |
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" |
17/09/84 |
DAFFE/CFA/WP1/84.1rev1 |
WP1 - CFA - OECD |
- |
En |
- |
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 |
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 |
§ / 17,18,19,20,21 |
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 |
§ / 17,18,19,20,21,22 |
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 |
VII / 4 |
Thin Capitalization; Discussion on the note
DAFFE/CFA/WP1/90.6 |
08/04/91 |
DAFFE/CFA/WP1/M(90)2/CORR1 |
WP1 - CFA - OECD |
- |
- |
- |
Correction of the document DAFFE/CFA/WP1/M(90)2 |
09/08/93 |
DAFFE/CFA/WP1(93)5 |
WP1 - CFA - OECD |
- |
En |
F,L,C / 8,9,12 |
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 |
§ / 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 |
§ / 6,16 |
The document contains the probable texts and reservations of
the 1995 Update and additional items that have not been formally agreed |
30/06/95 |
DAFFE/CFA/WP1(95)5/REV1 |
WP1 - CFA - OECD |
- |
En |
IIA / 6 |
The document contains a discussion of the adopted amendments
and other issues to the 1995+ Model Convention |
17/08/95 |
DAFFE/CFA/WP1(95)5/REV2 |
WP1 - CFA - OECD |
- |
En |
IIA / 9,10,11 |
The document contains comments by Member states to the
previous version DAFFE/CFA/WP1(95)5/REV1; discussion of the adopted
amendments and other issues to the 1995+ Model Convention |
23/08/95 |
DAFFE/CFA/WP1/WD(95)17 |
WP1 - CFA - OECD |
- |
En |
35-37,96 / 5,11 |
Changes to the OECD model tax convention and its commentaries
from 1977-1995 and Current issues being considered by working party |
19/12/95 |
DAFFE/CFA(95)16 |
CFA - OECD |
- |
- |
§ / 6,21,25 |
1995 changes to the OECD Model Convention , changes to the
observation and reservation and organizational changes |
14/01/96 |
DAFFE/CFA/WP1(96)1 |
WP1 - CFA - OECD |
- |
En |
§ / 9 |
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 |
8,9 / 2,3 |
Next update to the Model Tax Convention: possible contents,
changes to the commentary, changes to reservations and proposed timetable |
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 |
21/02/97 |
DAFFE/CFA/WP1(97)3 |
WP1 - CFA - OECD |
- |
En |
A8 / 3 |
New proposals by the steering group; Rates of withholding tax
on dividends and interest |
22/08/97 |
DAFFE/CFA/WP1(97)14 |
WP1 - CFA - OECD |
- |
En |
IIIF / 13 |
Rates of withholding tax on dividends and interest ;
Proposals for the next update to the Model Tax Convention |
22/12/97 |
DAFFE/CFA/WP1/WD(95)13/REV6 |
WP1 - CFA - OECD |
- |
En |
53,13 / 13,50 |
Changes to the commentary of article 10; issues arising under
article 5 (permanent establishment) of the model tax convention |
|
|
|
|
|
|
|