Date |
Document |
Institution |
MCC |
Or Lan |
§ / Pages |
Summary |
29/03/58 |
FC/M(58)2 |
FC - OEEC |
- |
Fr |
X/ 8 |
Creation of WP11 composed by France and Belgium |
15/01/59 |
FC/WP11(59)1 |
WP11 - FC - OEEC |
FR, BE |
Fr |
- |
Extensive report containing a general analysis, similar
clauses from existing double taxation agreements and a Draft Article |
20/01/59 |
FC/WP11(59)1 (Corr) |
WP11 - FC - OEEC |
FR, BE |
En! |
- |
Various changes to report FC/WP11(59)1 |
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 |
- |
En |
X/ 12 |
Discussion about the issues contained in report FC/WP11(58)1 |
17/03/59 |
TFD/FC/59 |
FC - OEEC |
IT |
Fr |
- |
The Italian Delegation takes the position that interest should
be taxed in the State of source |
28/04/60 |
FC/M(60)2 |
FC - OEEC |
- |
Fr |
III/ 9 |
Extensive discussion on the attribution of taxing rights in
the State of source in the light of report FC/WP11(59)1 |
03/05/60 |
FC/WP11(60)1 |
WP11 - FC - OEEC |
FR, BE |
Fr |
- |
Report containing a new Draft Article and its Commentary |
06/05/60 |
TFD/FC/93 |
FC - OEEC |
- |
Fr |
- |
Proposed amendments to document FC/M(60)2 |
28/05/60 |
FC/M(60)3 |
FC - OEEC |
- |
Fr |
V/ 13 |
Discussion on report FC/WP11(60)1 |
09/06/60 |
TFD/FC/98 |
WP11 - FC - OEEC |
FR, BE |
Fr |
- |
Comparable table of proposals by the Working Parties |
05/08/60 |
TFD/FC/102 |
FC - OEEC |
CH |
Fr |
- |
Note by the Swiss Delegation regarding the treatment of
excessive interest and royalties |
20/10/60 |
FC/WP11(60)2 |
WP11 - FC - OEEC |
FR, BE |
Fr |
- |
Report on difficult topics regarding the taxation of interests |
23/12/60 |
FC/M(60)6 |
FC - OEEC |
- |
Fr |
IV/ 8 |
Discussion on report FC/WP (60)2 |
19/01/61 |
TFD/FC/108 |
FC - OEEC |
- |
- |
- |
Draft amendment |
19/01/61 |
TFD/FC/109 |
FC - OEEC |
- |
- |
- |
Second draft amendment |
17/02/61 |
FC/M(61)1 |
FC - OEEC |
- |
Fr |
V/ 11 |
Discussion on report FC/WP11(60)2, on taxation at source and
on the safeguard clause |
01/03/61 |
FC/WP11(61)1 |
WP11 - FC - OEEC |
FR, BE |
Fr |
- |
New Draft Article and its Commentary |
10/03/61 |
TFD/FC/114 |
FC - OEEC |
NL |
- |
- |
Proposal by the Dutch Delegation on paragraph 5 |
31/03/61 |
FC/M(61)2 |
FC - OEEC |
- |
Fr |
IV/ 8 |
Discussion on report FC/WP11 (61)1 |
31/03/61 |
TFD/FC/116 |
FC - OEEC |
- |
Fr |
- |
Note collecting the various reservations on the Article |
10/04/61 |
FC/WP11(61)2 |
WP11 - FC - OEEC |
FR, BE |
Fr |
- |
Revised report containing a Draft Article, its Commentary and
Reservations |
19/04/61 |
TFD/FC/122 |
FC - OEEC |
UK |
- |
- |
Proposal from the British Delegation for an amendment of
paragraph 5 |
19/04/61 |
TFD/FC/124 |
FC - OEEC |
- |
Fr |
- |
New text of paragraph 6 and comments thereon |
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 |
V/ 7 |
Discussion on report FC/WP11(61)2 and on the proposals
submtted; adoption of the Article and its Commenrary; 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 |
§/22-23 |
Article text revised |
21/02/63 |
FC(63)2 |
FC - OECD |
- |
En & Fr |
§ / 15 |
Latest draft model convention. |
22/05/63 |
TFD/FC/158 |
FC - OECD |
US |
En |
IV(A) / 4-5 |
US criticism (requiring further study) - no guidance about
what amounts which might be considered to be excessive; how to determine when
a special relationship; how the excess amount of payment should be
characterized. |
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 |
V / 14-15(App) |
US Criticism: problems with the definiton of interest -
amounts included; debt-claims secured by mortgages; government securities;
inclusion of discount - proposal of a new wording of Art. 11(3). |
08/09/64 |
TFD/FC/173 |
FC - OECD |
JP |
En |
§ / 6 |
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 international definition of interest 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 |
§ / 34-37 |
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 |
§ / 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 |
- |
§ / 13 |
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 |
§ / 14-17 |
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 |
§ / 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 |
§ / 16 |
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 |
CA DE PT UK BE |
En & Fr |
§ / 33-35 |
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 |
FR LU |
En & Fr |
§ / 7 |
New WP27 comprising FR & LU formed for working on Articles
11 and 12. |
16/09/67 |
TFD/FC/222 |
FC - OECD |
- |
En |
§ / 44-49 |
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 |
§ / 115 |
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! |
§ / 22-24 |
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 |
37-41/22-24 |
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. |
30/12/68 |
FC/WP27(68)1 |
WP27 - FC - OECD |
- |
Fr |
3-5 / 1-5 |
Important for the meaning of the words "paid to":
suggestion to replace the term "paid" with "allotted"
declined, because: "the term “to pay” is employed
in the sense of the civil law and means “to fulfil the obligation to put
funds at the disposal of the creditor in the manner required by the contract
or by custom”. |
30/12/68 |
FC/WP27(68)1 |
WP27 - FC - OECD |
- |
Fr |
6-12/6-9 |
Consideration for the redrafting of definition of interest to
make it international/global (not dependent on internal laws?). |
30/12/68 |
FC/WP27(68)1 |
WP27 - FC - OECD |
- |
Fr |
13 / 9-10 |
Discussion leading to the insertion of reference to
"fixed base" and "independent personal services" in the
text of Art.11(4) of the 1977 OECD Model. |
30/12/68 |
FC/WP27(68)1 |
WP27 - FC - OECD |
- |
Fr |
14-15/10-11 |
Discussion about when interest arises in the payor's PE State
- no clear conclusion. |
30/12/68 |
FC/WP27(68)1 |
WP27 - FC - OECD |
- |
Fr |
16 / 11 |
discussion on whether the wording of 11(6) is adequate to
qualify the excess amount of interest payments. |
14/02/69 |
DAF/FC/69.5 |
FC - OECD |
- |
- |
A / 1-3 |
Notes on the discussions concerning interest and royalties at
the 30th session of the fiscal committee. |
16/05/69 |
DAF/FC/69.8 |
FC - OECD |
- |
En |
92-101/64-69 |
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 |
225-227/170-171 |
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. |
30/05/69 |
FC/WP27(69)1 |
WP27 - FC - OECD |
LU FR NL |
Fr |
- |
Draft addition to the Commentary on Article 11 of the 1963
Draft, which would form a supplement to Section E entitled “Solution adopted
by the Fiscal Committee of O.E.C.D.”, continuing as from paragraph 17. |
04/07/69 |
DAF/FC/69.10 |
WP27 - FC - OECD |
LU FR NL |
En |
- |
Note on the discussion of the first report of WP27 of the
Fiscal Committee on Interest and Royalties during the 31st session of the FC. |
16/02/70 |
FC/WP27(70)1 |
WP27 - FC - OECD |
LU FR NL |
Fr |
3-16 / 3-9 |
Report on suggested amendments to Articles 11 of the Draft
Convention, relating to interest. |
16/02/70 |
FC/WP27(70)1 |
WP27 - FC - OECD |
LU FR NL |
Fr |
24 / 12-14 |
Report on suggested amendments to Articles 11 and 12 of the
Draft Convention, relating to interest and royalties respectively. |
04/06/70 |
FC(70)1 |
FC - OECD |
- |
En |
92-101 / 53-57 |
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 |
225-227 / 134-135 |
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 |
DAF/FC/70.8 |
FC - OECD |
- |
En |
A (1-6, 8) / 1-3 |
Discussion of the 2nd report of WP27 [FC/WP27(70)1 dt
16/02/70]: exclusion of certain kinds of interest?; whether the definition of
interest should rely on internal laws?; reference to fixed base; source rule. |
04/11/70 |
FC/WP27(70)2 |
WP27 - FC- OECD |
LU FR NL |
Fr |
§ / 2-9 |
Proposals to amend Article 11, and commentaries thereon. |
14/01/71 |
FC(71)1 |
FC - OECD |
- |
En |
§ / 2-3, 4-12 |
Changes to the text of Article 11 and commentaries thereto. |
11/02/71 |
DAF/FC/71.4 |
FC - OECD |
- |
En & Fr |
- |
Modifications to the summary record and notes on the 37th
session of the FC contained in [FC/M(70)4 of 10/12/70, DAF/FC/70.14 dt
16/12/70, and FC(71)1 dt 14/01/71]. |
05/03/71 |
FC(71)1 (Corr) |
FC - OECD |
- |
En |
- |
Corrigendum to FC(71)1 dt 14/01/71. |
10/11/71 |
CFA(71)10 |
CFA - OECD |
- |
Fr & En |
§ / 6-7, 26-39 |
Revised text of Article and Commentary as unanimously approved
by the Fiscal Committee or by Working Party N° 1. |
21/01/72 |
CFA/WP1(72)1 |
WP26 - 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. |
10/02/72 |
CFA(71)10 (1st Revision) |
CFA - OECD |
- |
En & Fr |
§ / 7, 24-37 |
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 |
16 / 5 |
Can partnerships as such enjoy the benefits of Article 11? |
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 |
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 |
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 |
23 / 20,21 |
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 |
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 |
§ / 67 |
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 |
- |
- |
§ / 30,32 |
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 |
- |
- |
§ / 18 |
Part 4: Reservations on the Articles |
01/03/77 |
CFA (76)7part2rev1 |
WP1 - CFA - OECD |
- |
Fr & En |
§ / 30,32 |
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)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 |
§ / 12 |
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 / p3 |
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 / p38 |
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 |
6 / 13 |
The document contains the main differences between the OECD
and the United States Model Convention |
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 |
§ / 22,23 |
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 |
§ / 23,24 |
3rd Revision of the Observations and Reservations of the 1977
Model Convention; Answers received from the letter CFA(88)254 of 3rd October
1988. |
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 |
15/12/92 |
DAFFE/CFA/WP1/M(92)2 |
WP1 - CFA - OECD |
- |
En |
V / 4 |
Discussion of the relationship with the new Financial
instruments and the Article |
04/03/93 |
DAFFE/CFA/WP1/M(93)1 |
WP1 - CFA - OECD |
- |
En |
VI/ 4,5,6 |
Amendments on the UK´s reservations of the article |
09/08/93 |
DAFFE/CFA/WP1(93)5 |
WP1 - CFA - OECD |
- |
En |
F,C / 8,12 |
The application of the model tax convention to partnerships,
trusts and other non-corporate entities |
01/02/94 |
DAFFE/CFA/WP1(94)1 |
WP1 - CFA - OECD |
- |
En |
- |
Changes to the commentary resulting from the taxation of new
financial instruments document [DAFFE/CFA(94)12] |
31/05/94 |
DAFFE/CFA/WP1(94)1/REV1 |
WP1 - CFA - OECD |
- |
En |
- |
1st Revision of the document DAFFE/CFA/WP1(94)1;
Changes to the commentary resulting from the taxation of new financial
instruments and alternative solutions. |
14/06/94 |
DAFFE/CFA/WP1(94)1/REV2 |
WP1 - CFA - OECD |
- |
En |
- |
2nd Revision of the document DAFFE/CFA/WP1(94)1;
Changes to the commentary resulting from the taxation of new financial
instruments and alternative solutions. |
26/08/94 |
DAFFE/CFA/WP1/MR(94)14 |
WP1 - CFA - OECD |
- |
En |
§ / 4 |
The document contains the discussion of drafting the Model Tax
Convention in sex-neutral language |
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 |
04/11/94 |
DAFFE/CFA/WP1/MR(94)17 |
WP1 - CFA - OECD |
- |
En |
III (5) / 6 |
Sex-Neutral Language; Discussion of the issues (Preparing for
the 1995 update) of the note DAFFE/CFA/WP1/MR(94)6/REV1 |
08/11/94 |
DAFFE/CFA/WP1(94)9 |
WP1 - CFA - OECD |
- |
En |
§ / 7,16 |
The document contains the probable texts and reservations of
the 1995 Update and additional items that have not been formally agreed |
05/12/94 |
DAFFE/CFA(95)15 |
CFA - OECD |
- |
En |
- |
Comments on proposed changes to the model tax convention and
the commentaries relating to the taxation of new financial instruments |
03/02/95 |
DAFFE/CFA/WP1(95)6 |
WP1 - CFA - OECD |
- |
En |
§ / 6 |
Proposed changes to the model tax convention and commentaries
in response to the report on the taxation of new financial instruments |
30/06/95 |
DAFFE/CFA/WP1/WD(95)14 |
WG2 - WP1 - CFA - OECD |
- |
En |
15/ 4 |
The cross-border pension payments and related issues ;Replies
to the pension questionnaire |
23/08/95 |
DAFFE/CFA/WP1/WD(95)17 |
WP1 - CFA - OECD |
- |
En |
38-41,96/ 5,11 |
Changes to the OECD model tax convention and its commentaries
from 1977-1995 and Current issues being considered by working party |
25/08/95 |
DAFFE/CFA/WP1/WD(95)14/REV1 |
WG2 - WP1 - CFA - OECD |
- |
En |
17 / 4 |
1st revision of the cross-border pension payments and related
issues ;Replies to the pension questionnaire |
12/09/95 |
DAFFE/CFA/WP1/MR(95)2/REV3 |
WP1 - CFA - OECD |
- |
En! |
IE / 6 |
Preparing for the 1995+update; Drafting the Model in
Gender-Neutral Language |
19/12/95 |
DAFFE/CFA(95)16 |
CFA - OECD |
- |
- |
§ / 7,21,26 |
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 |
ID / 5 |
Drafting the English Version of the Model in Gender-Neutral
Language; Working party proposals for the 1995+ update to the model tax
convention |
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 |
10 / 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 |
IVD / 5,24 |
Proposals for the next update to the model tax convention |
23/10/96 |
DAFFE/CFA/WP1(96)19 |
WP1 - CFA - OECD |
- |
En |
A / 4 |
New proposals by the steering group on the Model Tax
Convention |
11/02/97 |
DAFFE/CFA/WP1(97)6 |
WP1 - CFA -OECD |
- |
En |
B3 / 4 |
Changes to the Articles of
fall 1997 update to 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 |
21/02/97 |
DAFFE/CFA/WP1(97)3 |
WP1 - CFA -OECD |
- |
En |
A / 2 |
New proposals by the steering group; Rates of withholding tax
on dividends and interest |
20/08/97 |
DAFFE/CFA/WP1(97)12 |
WP1 - CFA -OECD |
- |
En |
22 / 9 |
Slovakia’s positions (reservations) on the model tax
convention |
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 - OEC |
- |
En |
53,14 / 13,50 |
Changes to the commentary of article 11; issues arising under
article 5 (permanent establishment) of the model tax convention |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|