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 |
12/02/58 |
FC/WP8(58)1 |
WP8 - FC - OEEC |
DE, LU |
Fr & En |
- |
Report containing a Draft Article, its Commentary and a few
examples of similar clauses from st the time current double taxation
agreements |
06/05/58 |
TFD/FC/38 |
FC - OEEC |
CH |
Fr & En |
- |
Proposal from the Swiss Delegation on the wording of the
Article |
16/06/58 |
FC/M(58)3 |
FC - OEEC |
- |
Fr |
III/ 8 |
Discussion on Report FC/WP8(58)1 and Proposal TFD/FC/38 |
03/09/58 |
FC/WP8(58)2 |
WP8 - FC - OEEC |
DE, LU |
Fr |
- |
Second Report containing a revised Draft Article; in the
annex, explanations on the current paragraph 4 (not inserted in the Draft
Article) are provided |
31/10/58 |
FC/M(58)4 |
FC - OEEC |
- |
Fr |
V/ 7 |
Extensive discussion on whether and, if so, to what extent a
right to tax should be given to the State of source |
10/11/58 |
FC/WP8(58)3 |
WP8 - FC - OEEC |
DE, LU |
Fr |
- |
WP8 proposes amendments with regard to taxation of Royalties
in the State of source; Swiss proposal on the deductibility of Royalties |
19/11/58 |
TFD/FC/48 |
FC - OEEC |
PT |
Fr |
- |
Proposal by the Portuguese Delegation for taxation of
Royalties in the State of source |
02/12/58 |
TFD/FC/51 |
FC - OEEC |
BE |
Fr |
- |
Note by the Belgian Delegation the principles of tax
allocation |
16/12/58 |
FC/M(58)5 |
FC - OEEC |
- |
Fr |
VIII/ 9 |
Discussion centered on the definition of Royalties and on
whether the State of source should be granted taxing rights |
19/12/58 |
FC/WP8(58)4 |
WP8 - FC - OEEC |
DE, LU |
Fr |
- |
WP8 informs the Delegations on how it intends to deal with the
issues raised in the previous documents |
19/01/59 |
TFD/FC/53 |
FC - OEEC |
IT |
Fr |
- |
Proposed amendment by the Italian Delegation |
28/04/60 |
FC/M(60)2 |
FC - OEEC |
- |
Fr |
IV/ 14 |
Extensive discussion based on report FC/WP8(58)4 |
03/05/60 |
FC/WP8(60)1 |
WP8 - FC - OEEC |
DE, LU |
Fr |
- |
Proposed agreement containing a new Draft Article and
questions on further topics |
09/06/60 |
TFD/FC/98 |
WP8 - FC - OEEC |
DE, LU |
Fr |
- |
Comparable table of proposals by the Working Parties |
18/08/60 |
FC/WP8(60)2 |
WP8 - FC - OEEC |
DE, LU |
Fr |
- |
New Draft Article |
05/08/60 |
TFD/FC/102 |
FC - OEEC |
CH |
Fr |
- |
Note by the Swiss Delegation regarding the treatment of
excessive interest and royalties |
12/10/60 |
FC/M(60)5 |
FC - OEEC |
- |
Fr |
VII/ 8 |
Discussion on report FC/WP8(60)2 |
23/12/60 |
FC/M(60)6 |
FC - OEEC |
- |
Fr |
B/ 6 |
Discussion on the Draft Article |
17/02/61 |
FC/M(61)1 |
FC - OEEC |
- |
Fr |
IV/ 7 |
Discussion on whether to allow the State of source to tax the
income |
27/02/61 |
FC/WP8(61)1 |
WP - FC - OEEC |
DE, LU |
Fr |
- |
Revised Draft Article and its Commentary |
31/03/61 |
FC/M(61)2 |
FC - OEEC |
- |
Fr |
III/ 5 |
Discussion on the new Draft Article in report FC/WP8(61)1 |
31/03/61 |
TFD/FC/116 |
FC - OEEC |
- |
Fr |
- |
Note collecting the various reservations on the Article |
04/04/61 |
FC/WP8(61)2 |
WP - FC - OEEC |
DE, LU |
Fr |
- |
Revised report containing a Draft Article, its Commentary and
Reservations on the Article |
19/04/61 |
TFD/FC/123 |
FC - OEEC |
- |
- |
- |
New text of the comments on paragraph 4 |
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 |
II/ 3 |
Discussion on report FC/WP8(61)2; adoption of the Article and
its Commentary; 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 |
§/24-25 |
Article text revised |
21/02/63 |
FC(63)2 |
FC - OECD |
- |
En & Fr |
§ / 16 |
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. |
05/08/64 |
FC(64)1 |
FC - OECD |
JP |
En |
§4 / 2 |
Japan reserves its right to tax under Art. 12(1) royalties and
gains from the alienation of property giving rise to royalties. |
06/02/67 |
TFD/FC/208 |
FC - OECD |
- |
En |
§ / 38-41 |
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 |
§ / 10 |
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 |
- |
§ / 14 |
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 |
§ / 18-21 |
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 |
§ / 6 |
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 |
§ / 17 |
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 GR CA FR PT UK BE |
En & Fr |
§ / 36-37 |
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 |
§ / 50-53 |
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 |
§ / 116 |
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! |
§ / 25-27 |
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 |
42-45/25-27 |
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 |
17-18/11 |
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 |
19-25/12-15 |
Discussions about the definition of royalties. |
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 |
102-111/70-75 |
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 |
228-230/171-172 |
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. |
16/02/70 |
FC/WP27(70)1 |
WP27 - FC - OECD |
LU FR NL |
Fr |
17-23 / 9-12 |
Report on suggested amendments to Articles 12 of the Draft
Convention, relating to royalties. |
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 |
102-111 / 58-63 |
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 |
228-230 / 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 (7-8) / 1-3 |
Discussion of the 2nd report of WP27 [FC/WP27(70)1 dt
16/02/70]: scope of Article 12, and its interaction with Articles 5&7,
14, and 17. |
04/11/70 |
FC/WP27(70)2 |
WP27 - FC- OECD |
LU FR NL |
Fr |
Sep-13 |
Proposals to amend Article 12 and commentaries thereon. |
14/01/71 |
FC(71)1 |
FC - OECD |
- |
En |
§ / 3, 12-18 |
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 |
§ / 7, 39-47 |
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 |
§ / 8, 37-45 |
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 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 |
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-residents |
21/05/75 |
CFA/WP1(75)3 |
WG21 - WP1 - CFA - OECD |
US,DK,DE |
En |
24 / 21-22 |
Improper use and abuse
of tax conventions |
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 |
43 / 9 |
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 |
§ / 73 |
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 |
- |
- |
§ / 34 |
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 |
- |
- |
§ / 20 |
Part 4: Reservations on the Articles |
01/03/77 |
CFA (76)7part2rev1 |
WP1 - CFA - OECD |
- |
Fr & En |
§ / 34 |
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 / 7 |
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 |
§ / 14 |
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 |
10-20 / 3-5 |
The document shows problems with non-Member countries and the
application of Article 12 |
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] concerning the problems
with non-Member countries and the application of Article 12 |
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 / 41 |
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 |
7 / 13 |
The document contains the main differences between the OECD
and the United States Model Convention |
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. |
14/03/79 |
DAF/CFA/WP1/79.6 |
WP1 - CFA - OECD |
FR, DE, NL, CH, UK, US |
En & Fr |
- |
Comments by the six countries on a multilateral convention on
copyright royalties |
25/05/79 |
DAF/CFA/79.4 |
CFA - OECD |
- |
- |
- |
Comments on the UNESCO-WIPO
draft Convention, which is provided in full |
18/06/79 |
DAF/CFA/79.4 (Add) |
CFA - OECD |
- |
Fr & En |
- |
Addendum to the French text of doc DAF/CFA/79.4 |
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 |
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 |
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 |
15/09/86 |
DAFFE/CFA/WP1/86.8 |
WP1 - CFA - OECD |
- |
En |
1 / 5 |
BIAC's report on the tax problems arising with softwares |
08/01/87 |
DAFFE/CFA/86.25 |
CFA - OECD |
- |
En |
1 / 2 |
BIAC's review of tax issues related to specific articles of
the 1977 OECD MC; the document is submittee to the CFA for information |
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 |
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 |
§ / 24,25,26 |
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 |
§ / 25,26,27 |
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) |
26/04/91 |
DAFFE/CFA/WP1/M(91)1 |
WP1 - CFA - OECD |
- |
En |
VI / 5 |
Revision of the 1977 Model; The leasing of Industrial,
Commercial and Scientific Equipment and Leasing of Containers was approved
subject to changes in the commentary |
11/10/91 |
DAFFE/CFA/WP1/M(91)2 |
WP1 - CFA - OECD |
- |
En |
V / 3 |
The tax treatment of Software amendments to the Commentary |
09/01/92 |
DAFFE/CFA(92)1/ADD1 |
CFA - OECD |
CA,PT |
- |
- |
Tax Treatment of Software; the document contains observations
and reservations of the amendments of the commentary |
30/01/92 |
DAFFE/CFA/WP1(92)2 |
WP1 - CFA - OECD |
US |
- |
- |
United States proposed addition to the note on the tax
treatment of software; Amendments of
the Commentary of the Article |
11/02/92 |
DAFFE/CFA/WP1/WD(92)1 |
WP1 - CFA - OECD |
AU |
- |
- |
This document is not available; Australia´s proposal of the
Tax Treatment of Software |
18/02/92 |
DAFFE/CFA/M(92)1 |
CFA - OECD |
- |
En |
VI / 4 |
The Committee approved the report DAFFE/CFA(92)1 and
Addendum |
09/03/92 |
DAFFE/CFA/WP1/M(92)1 |
WP1 - CFA - OECD |
- |
En |
III / 2 |
Discussion of the WP concerning the proposals of Australia and
USA and the approval of the document [DAFFE/CFA/WP1(90)4/REV3]. |
09/08/93 |
DAFFE/CFA/WP1(93)5 |
WP1 - CFA - OECD |
- |
En |
C / 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 |
§ / 4,5 |
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 |
II / 3 |
Treatment od software; 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 |
§ / 8,17 |
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 |
42-45,97-99 / 6,11 |
Changes to the OECD model tax convention and its commentaries
from 1977-1995 and Current issues being considered by working party |
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 |
- |
- |
p8,21,25 |
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 |
IA / 2,3 |
Beneficial Ownership of Royalties; Working party proposals for
the 1995+ update to the model tax convention |
14/01/96 |
DAFFE/CFA/WP1(96)1 |
WP1 - CFA - OECD |
- |
En |
§ / 10 |
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 |
4,10 / 2,3 |
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 |
IIIF,I,IVA / 21,22 |
Proposals for the next update to the model tax convention |
23/10/96 |
DAFFE/CFA/WP1(96)19 |
WP1 - CFA - OECD |
- |
En |
B / 5 |
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, Reservations and Observations 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 |
B / 3,4 |
New proposals by the steering group; Source rule for
royalties |
06/03/97 |
DAFFE/CFA/WP1(97)9 |
WP1 - CFA - OECD |
- |
En |
- |
Suggestions for the change to the commentary paragraphs 12-17
on article 12 concerning software payments |
11/07/97 |
DAFFE/CFA/WP1/MR/M(97)1 |
WP1 - CFA - OECD |
- |
En |
IIIB / 3 |
Discussion of WP1 concerning the meaning of royalties in
paragraph 18 of the Commentary on Article 12 of document
DAFFE/CFA/WP1/MR(96)2/REV1 |
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 |
IIIB,G / 11,14 |
Goods and services not attributable to a permanent
establishment and Source rule for
royalties ; Proposals for the next
update to the Model Tax Convention |
27/08/97 |
DAFFE/CFA/WP1(97)11 |
WP1 - CFA - OECD |
- |
En |
- |
The document contains some of the characterization issues
arising out electronic commerce, with particular focus on transactions
relating to digital products. |
22/12/97 |
DAFFE/CFA/WP1/WD(95)13/REV6 |
WP1 - CFA - OECD |
- |
En |
53,15 / 13,50 |
Changes to the commentary of article 12; issues arising under
article 5 (permanent establishment) of the model tax convention |
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