Date |
Document |
Institution |
MCC |
Or Lan |
§ / Pages |
Summary |
03/07/57 |
C(57)145 |
FC - OECC |
- |
Fr |
II(12)/ 5 |
List of the new five Working Parties |
11/09/57 |
FC/WP10(57)1 |
WP10 - FC - OECC |
SE |
En |
B(a)(1)(2)(3) / 4 - 5 |
Report, Draft Article and Commentary |
06/01/58 |
FC/M(58)1 |
WP10 - FC - OECC |
- |
Fr |
IV/ 4 |
Comments on the report FC/WP10(57)1 |
31/01/58 |
FC/WP10(58)1 |
WP10 - FC - OECC |
SE |
En |
- |
Report, Draft Article and Commentary |
28/04/58 |
TFD/FC/34 |
FC - OECC |
- |
Fr & En |
- |
Redraft of the Article |
31/10/58 |
FC/M(58)4 |
FC - OECC |
- |
Fr |
III/ 6 |
Adoption of the Draft Article in Report TDF/FC/34 with
amendments |
30/12/58 |
FC(58)7 |
FC - OECC |
- |
En |
- |
Draft Article submitted to the Committee for adoption |
11/04/59 |
TFD/FC/62 |
FC - OECC |
- |
Fr |
- |
List of observations on the drafting of the Article |
11/04/59 |
TFD/FC/63 |
FC - OECC |
- |
Fr & En |
- |
Text of the Article for harmonisation |
21/04/59 |
TFD/FC/63rev1 |
FC - OECC |
- |
Fr & En |
- |
Text of the Article after revision by the Drafting Group |
21/05/59 |
FC(59)2 |
FC - OECC |
- |
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 - OECC |
- |
Fr & En |
- |
Final text of the Article, annex to Recommendation TFD/FC/66 |
26/01/62 |
TFD/FC/137 (1st Revision) |
Drafting Group - FC - OECD |
- |
Fr & En |
§/26-27 |
Article text revised |
19/02/62 |
FC/M/(62)1 |
FC - OECD |
- |
Fr |
II / 5 |
In the English version "pedagogic activities is
replaced by « teaching activities » in Art. VI (e) (CMC Art.
14); « the independent activities of physicians, etc. »
is added to te same §. Insertion of the definition of « professional
services » in Art. VI (CMC Art. 14 deleted) on taxation of independent
personal services on request of AT. |
28/02/62 |
FC/WP14(62)2 |
WP14 - FC - OECD |
AT SE |
En |
Intro / 1-2 |
Report prepared by WP14 in the light of the discussions of the
FC at its last session in January, 1962; (e) regarding professional services
will not be included in Art. 3 but in Art. 14 (deleted) instead, in
conformity with what was decided during the last session. |
11/04/62 |
FC/M(62)2 (Part1) |
FC - OECD |
- |
Fr |
A, B(a) / 2, 3, 4 |
Definition of and commentary on "professional
services" shifted from Art. 3(1) to separate article for income from
"professional services". "Artistic" activities added to
the definition of professional services.. |
21/02/63 |
FC(63)2 |
FC - OECD |
- |
En & Fr |
§ / 18 |
Latest draft model convention. |
22/05/63 |
TFD/FC/158 |
FC - OECD |
US |
En |
IV(A) / 4-5(App) |
Unresolved issues requiring further study listed by the US -
attribution and computation of income to a PE / Fixed Base. |
22/05/63 |
TFD/FC/158 |
FC - OECD |
US |
En |
VII / 17-18(App) |
US Criticism: (A) What is the distinction between business
profits and independent personal services?; (B) lack of guidance regarding
the meaning, time issues, existence or use of a fixed base. |
14/11/66 |
TFD/FC/202 |
FC - OECD |
- |
En & Fr |
A / 2 |
Questions relating to allocation of profits to a fixed base in
the 1963 Draft Convention left for future discussion by the FC: paragraph of
1963 Report in which question was raised: 21; Working Party in charge: -. |
14/04/67 |
TFD/FC/214 |
FC - OECD |
- |
En |
§ / 25-27 |
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 |
§ / 7 |
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 |
NO FR |
En & Fr |
§ / 19 |
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 |
GR NO FR |
En & Fr |
§ / 39-41 |
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 |
DE IE SE |
En & Fr |
§ / 7 |
New WP28 comprising DE IE & SE formed for working on
Articles 1, 4, 14-20 & 21, including issues of annuities and residence of
diplomats. |
16/09/67 |
TFD/FC/222 |
FC - OECD |
- |
En |
§ / 58-59 |
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 |
§ / 118 |
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! |
§ / 28-31 |
Analysis of conformity with or deviation from the 1963 OECD
Draft Convention in tax treaties between OECD and developing countries. |
21/06/68 |
FC/WP28(68)1 |
WP28 - FC - OECD |
DK IE SE |
En |
16-17 / 3 |
1st Report of WP28: brief survey of some deviations in recent
tax treaties. |
21/10/68 |
FC(68)1 |
FC - OECD |
- |
En |
46-53/28-31 |
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 |
125-129/82-85 |
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 |
232-233/172-173 |
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 |
125-129 / 69-70 |
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 |
232-233 / 136 |
Analysis of deviations of protocols concluded amongst member
countries, between 01/07/63 and 01/01/69 from the 1963 OECD Draft. |
28/04/71 |
CFA(71)3 |
CFA - OECD |
- |
En |
- |
Organisation of work under the CFA: Report expected June 1971:
possible conclusion by end of 1971. |
23/09/71 |
DAF/CFA/WP1/71.5 |
WP1 - CFA - OECD |
- |
En |
VII / 3 |
WG28 to submit its report on Arts. 1, 4, 14-21 by the end of
the year. |
26/02/73 |
CFA/WP6(73)1 |
WP6 - CFA - OECD |
- |
Fr |
16 / 4 |
Problems with the personnel of Multinational Enterprises |
12/04/73 |
CFA/WP1(73)4 |
WG28 - WP1 - CFA - OECD |
DK,IR, SE |
En |
8 / 4 |
Remuneration of visiting professors, teachers and persons
engaged in research |
16/04/73 |
DLF/CFA/W P6/73.1 |
WP6 - CFA - OECD |
- |
En |
§ / 11 |
Drafted Report on The Problems with the personnel of
Multinational Enterprises |
21/05/73 |
CFA(73) 4 |
WP6 - CFA - OECD |
- |
En |
§ / 11 |
Problems with the personnel of Multinational Enterprises |
14/11/73 |
CFA/W151(73)13 |
WG28 - WP1 - CFA - OECD |
DK,IR, SE |
En |
18 / 3 |
Proposed amendments to paragraph 1,2 of Article 14 (183 days
rule) |
14/01/74 |
DAF/CFA/WP1(74)2 |
WP1 - CFA - OECD |
- |
Fr |
III / 3 |
The chairman decided that it was not desirable to include the
183 days rule of the first report of Working Group No. 28, CFA/WP1(73)13 of
14th November, |
15/03/74 |
DAF/CFA/WP1/74.4 |
WP1 - CFA - OECD |
- |
Fr |
1,2 / 1 |
Working Party No1 Examinations of the report of Working Group
No. 28 CFA/WP1(73)13 of 14th November, 1973 and reservations of the Article |
18/04/74 |
CFA/WP1(74)3 |
WG28 - WP1 - CFA - OECD |
DK,IR, SE |
En |
3 / 2 |
The WP decided not to amend the text of the Article but agreed
to state more clearly the same principles as those of Article 7 on business
income |
22/10/74 |
DAF/CFA/WP1/74.17 |
WP1 - CFA - OECD |
- |
Fr |
4 / 1 |
The Working Party adopted the revised texts of Articles 14 and
15, together with the corresponding Commentaries proposed by Working Group
No. 28 [CFA/WP1(74)3 of 18th April, 1974] |
12/02/75 |
DAF/CFA/WP1/75.4 |
WG28 - WP1 - CFA - OECD |
DK,IR, SE |
En |
- |
The Working Group No 28
present the final versions of Articles 14,and the Commentary taking account
of the discussions at the Working Party’s meeting in December, 1974. |
17/02/75 |
DAF/CFA/WP1/75.4 (Add) |
WG28 - WP1 - CFA - OECD |
DK,IR, SE |
En & Fr |
- |
Reservation of Portugal, amendment to the document
DAF/CFA/WP1/75.4 |
15/03/75 |
CFA/WP1(75)2 |
WG30 - WP1 - CFA - OECD |
AU,BE,CH |
En |
§ / 6 |
Examples and solutions of the
divergent interpretation of the Model-convention concerning the
taxation of partnerships. |
25/03/75 |
CFA/WP1(75)2 |
WG30 - WP1 - CFA - OECD |
AU,BE,CH |
En |
§ / 9 |
Examples and solutions of the
divergent interpretation of the Model-convention concerning the
taxation of partnerships. |
15/04/75 |
CFA(75)3 |
CFA - OECD |
- |
En & Fr |
- |
The document contains the result of the revision by Working
Party No. 1 of the Committee on Fiscal Affairs of Articles 14, 15, 18 and 20
and of the Commentary thereon |
21/05/75 |
CFA/WP1(75)3 |
WG21 - WP1 - CFA - OECD |
US,DK,DE |
En |
33 / 28,29 |
Improper use and abuse of tax conventions (personal services) |
08/07/75 |
CFA/M(75)2 |
CFA - OECD |
- |
En |
2 / 3 |
The Committee adopted the revised Articles 14, 15, 18, 20, 28,
29 and 30, and the Commentaries thereon. CFA(75)3 and CFA(75)7 |
10/07/75 |
CFA(75)13 |
CFA - OECD |
- |
- |
- |
The attached document contains the revised texts of Articles
14, 15, 18, 20, 28, 29 and 30 of the Draft Double Taxation Convention on
Income and Capital of 1963(This text CANCELS and REPLACES the English text of
the same document dated 9th July, 1975) |
16/07/75 |
C(75)126 |
CFA - OECD |
- |
En & Fr |
- |
The revised texts of Articles 14, 15, 18, 20, 28, 29 and 30
and Commentaries in document CFA(75)13
were adopted by the Committee on Fiscal Affairs at its 9th Session from
24th–26th June, 1975. |
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 |
§ / 87 |
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 |
- |
- |
§ / 38 |
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 |
- |
- |
§ / 24 |
Part 4: Reservations on the Articles |
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 |
§ / 18 |
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 / 4 |
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 / 46 |
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 |
9 / 14 |
The document contains the main differences between the OECD
and the United States Model Convention |
14/03/79 |
DAF/CFA/WP8/79.7 |
WG1 - WP8 - CFA - OECD |
- |
- |
- |
The WP asks the delegates how they dealt with the issue;
specific examples of common situations are provided in the report |
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 |
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 |
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 |
§ / 30,31 |
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 |
§ / 31,32 |
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 / 6 |
Revision of the 1977 Model;
The treatment of Entertainers, Artistes and Sportsmen was approved
subject to changes in the commentary |
09/08/93 |
DAFFE/CFA/WP1(93)5 |
WP1 - CFA - OECD |
- |
En |
J / 8 |
The application of the model tax convention to partnerships,
trusts and other non-corporate entities |
26/08/94 |
DAFFE/CFA/WP1/MR(94)14 |
WP1 - CFA - OECD |
- |
En |
§ / 5 |
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 |
§ / 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 / 4 |
Restricting articles 14,15 to individuals; Discussion of the
issues (Preparing for the 1995 update) of the note
DAFFE/CFA/WP1/MR(94)6/REV1 |
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 |
§ / 17,37 |
The document contains the probable texts and reservations of
the 1995 Update and additional items that have not been formally agreed |
15/02/95 |
DAFFE/CFA/WP1(95)5 |
WP1 - CFA - OECD |
- |
En |
§ / 4 |
Preparing for the 1996 Update; Recommendations of the Steering
Group |
30/06/95 |
DAFFE/CFA/WP1(95)5/REV1 |
WP1 - CFA - OECD |
- |
En |
IA / 2 |
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 |
IA/ 3 |
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 |
48,49,101/ 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 |
- |
- |
§ / 22 |
1995 changes to the OECD Model Convention and changes to the
observation and reservation |
20/12/95 |
DAFFE/CFA/WP1(95)5/REV3 |
WP1 - CFA - OECD |
- |
En |
ID,IIIA / 5,17 |
Working party proposals for the 1995+ update to the model tax
convention |
05/02/96 |
DAFFE/CFA/WP1(96)5 |
WP1 - CFA - OECD |
- |
En |
5,10 / 2,3 |
Next update to the Model Tax Convention: possible contents,
changes to the commentary, changes to reservations and proposed timetable |
11/06/96 |
DAFFE/CFA/WP1(96)12 |
WG5 - WP1 - CFA - OECD |
- |
En |
- |
The document contains issues related to article 14 of the
model tax convention |
03/07/96 |
DAFFE/CFA/WP1(96)12/REV1/ANN1 |
WG5 - WP1 - CFA - OECD |
- |
En! |
- |
1st revision of the issues related to article 14 of the model
tax convention |
04/07/96 |
DAFFE/CFA/WP1(96)12/REV1 |
WG5 - WP1 - CFA - OECD |
- |
En! |
- |
1st revision of the issues related to article 14 of the model
tax convention |
12/08/96 |
DAFFE/CFA/WP1(96)12/REV2 |
WG5 - WP1 - CFA - OECD |
- |
En |
- |
2nd revision of the issues related to article 14 of the model
tax convention |
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 |
04/11/96 |
DAFFE/CFA/WP1/M(96)2 |
WP1 - CFA - OECD |
- |
En |
V / 4 |
Discussion of the WP1 concerning Article 14 document
DAFFE/CFA/WP1(96)12/REV2 |
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 |
20/08/97 |
DAFFE/CFA/WP1(97)12 |
WP1 - CFA - OECD |
- |
En |
22 / 9 |
Slovakia’s positions (reservations) on the model tax
convention |
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