Date | Document | Institution | MCC | Or Lan | § / Pages | Summary |
02/10/56 | FC/WP5(56)1 | WP - FC - OEEC | BE, SE | Fr | B/ 9-13 | Report concerning the issue of double taxation and an overview of existing agreements; the WP recommends Member Countries to follow the principle of POEM when entering into double taxation agreements |
06/05/57 | FC/WP5(57)2 | WP - FC - OEEC | BE, SE | Fr | Ann I: 2/3, Ann III: B/15-17 | Revised report containing a Draft Recommendation and a Commentary on it |
05/06/57 | TFD/FC/15 | WP - FC - OEEC | BE, SE | Fr | - | New Draft paragraph 2 |
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 | WP - FC - OEEC | - | Fr | III/ 2 - 3 | Amendments to the Draft Recommendation (FC/WP5(57)2) |
11/09/57 | FC/WP10(57)1 | WP10 - FC - OEEC | SE | En | A(1)(2)/ 2 - 3 | Report, Draft Article and Commentary |
27/11/57 | TFD/FC/29 | WP5/WP6 - FC - OEEC | BE, SE, FR, DE | Fr | - | New Draft Article 8 |
29/11/57 | TFD/FC/WP5/WP6 | WP5/WP6 - FC - OEEC | BE, SE, FR, DE | Fr | - | Draft Article 8 adopted by the Committee |
19/12/57 | TFD/FC/29final | WP5/WP6 - FC - OEEC | BE, SE, FR, DE | Fr! | - | Final text of Article 8 (French only) |
06/01/58 | FC/M(58)1 | WP10, WP5/WP6 - FC - OEEC | - | Fr | IV/ 5, V/ 6-7, Annex II/ 10 | Comments on the report FC/WP10(57)1, approval of the Draft Article in report FC/WP6(57)1, and review of report TFD/FC/29 |
31/01/58 | FC/WP10(58)1 | WP10 - FC - OEEC | SE | En | - | Report, Draft Article and Commentary |
07/02/58 | FC/WP5(58)1 | WP5/WP6 - FC - OEEC | BE, SE, FR, DE | Fr | - | Final version of the Draft Article 8, with its Commentary, as adopted by the Committee |
13/02/58 | FC(58)2 | WP5/WP6 - FC - OEEC | - | Fr | - | Report on the work of the Committee and the results achieved; the text of Article 8 is provided in the annex, with an introductory explanation before |
24/02/58 | TFD/FC/30 | FC - OEEC | NO | En | - | Note from the Norwegian Delegate concerning the principles on which the provision is based |
07/03/58 | FC(58)3 | FC - OEEC | NO | En | - | Second note from the Norwegian Delegate concerning the principles on which the provision is based |
19/03/58 | TFD/FC/32rev | FC - OEEC | - | Fr & En | VI/ 6 | Suggestions for the Drafting Group on how to draft the Model and specific articles |
29/03/58 | FC/M(58)2 | FC - OEEC | - | Fr | IX/ 7 | Discussion on the issues raised in report FC(58)3, previously circulated as TDF/FC/30 |
28/04/58 | TFD/FC/34 | FC - OEEC | - | Fr & En | - | Redraft of the Article |
16/06/58 | FC/M(58)3 | FC - OEEC | - | Fr | III(B)/ 6 | Discussion on the issues raised by the Norway Delegation in report FC(58)3; deletion of the provision from Art 8 (paragraph 4) |
16/09/58 | FC(58)4 | FC - OEEC | - | Fr & En | - | Report containing a Draft Article, its Commentary and a second Memorandum by the Delegate from Norway, explaining why Norway deems the existing principle undesirable and proposes a different one |
19/09/58 | FC(58)4 | FC - OEEC | GR | En | B/ 8 | 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 | III/ 6, II/ 4 | Adoption of the Draft Article in Report TDF/FC/34 with amendments; amendments to Article 8 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 8 as approved and its Comemntary submitted for adoption |
20/11/58 | TFD/FC/49 | FC - OEEC | CH | Fr | - | Swiss proposal for a new wording of Article 8(4) |
30/12/58 | FC(58)7 | FC - OEEC | - | En | - | Draft Article submitted to the Committee 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 Revision) | Drafting Group - FC - OECD | - | Fr & En | §/26-27 | Article text revised |
21/02/63 | FC(63)2 | FC - OECD | - | En & Fr | § / 18 | Latest draft model convention. |
14/04/67 | TFD/FC/214 | FC - OECD | - | En | § / 27-28 | 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 | § / 7-8 | 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 | SE NO BE | En & Fr | § / 20 | 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 | SE NO BE | En & Fr | § / 42 | 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 | § / 60-63 | 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 | 18-21 / 3-4 | 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 | 130-135/86-89 | 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 | 130-135 / 71-73 | 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 | 28 / 5 | Proposed amendments to paragraph 2 of Article 15 |
15/03/74 | DAF/CFA/WP1/74.4 | WP1 - CFA - OECD | - | Fr | § / 2,3 | 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 | WP28 - WP1 - CFA - OECD | DK,IR, SE | En | 4,5,6 / 5,6 | The WP decided not to amend the text of the Article but agreed to modify the commentary paragraphs 3,4 (183 days rule) |
30/04/74 | CFA/WP1(74)3 | WP28 - WP1 - CFA - OECD | DK,IR, SE | En | - | The “183-day rule” has been prepared by the Rapporteur of Working Group N° 28 as an annex to the main report [CFA/WP1(74)3] of 18th April, 1974. |
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] |
29/01/75 | DAF/CFA/WP1/75.2 | WP1 - CFA - OECD | - | Fr | 3 / 7 | Rejected Proposal by the Delegate for Finland regarding Article 15 |
12/02/75 | DAF/CFA/WP1/75.4 | WP28 - WP1 - CFA - OECD | DK,IR, SE | En | - | The Working Group No 28 present the final versions of Articles 15,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) | WP28 - WP1 - CFA - OECD | DK,IR, SE | En & Fr | - | Reservation of Belgium, amendment to the document DAF/CFA/WP1/75.4 |
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 |
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 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. |
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 | § / 88 | 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 |
01/03/77 | CFA (76)7part2rev1 | WP1 - CFA - OECD | - | Fr & En | § / 38 | 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 |
07/03/77 | CFA(76)7part1rev1 | WP1 - CFA - OECD | - | En & Fr | - | 1st revision and final version of Part I CFA(76)7, Part I |
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 | 10 / p15 | The document contains the main differences between the OECD and the United States Model Convention |
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 |
16/09/82 | DAFFE/CFA/WP1/82.8 | WP8 - CFA - OECD | - | Fr | - | Report on the tax problems of the international hiring-out of labour |
08/06/83 | DAFFE/CFA/WP1/83.9 | WP1 - CFA - OECD | - | Fr | - | Abuse of certain thresholds and problem of the hiring-out of labour |
09/06/83 | DAFFE/CFA/WP1/83.3rev1 | WP1 - CFA - OECD | - | En | - | Report on the tax problems of the international hiring-out of labour and possible solutions |
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 |
02/10/89 | CFA/WP1/A(89)2 | WP1 - CFA - OECD | - | En | VI/ 4 | The WP agrees on the application of the 183-day rule |
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 | § / 32 | 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 | § / 33 | 3rd Revision of the Observations and Reservations of the 1977 Model Convention; Answers received from the letter CFA(88)254 of 3rd October 1988. |
11/10/91 | DAFFE/CFA/WP1/M(91)2 | WP1 - CFA - OECD | - | En | VI / 4 | Adoption of the Part VIII, Taxation Issues Relating to the International Hiring--out of Labour, with amendments to the document DAFFE/CFA/WP1(91)4/REV1 |
04/03/93 | DAFFE/CFA/WP1/M(93)1 | WP1 - CFA - OECD | - | En | VI / 4,5,6 | Creation of a working group for the application and interpretation of paragraph 2 of article 15 |
26/07/93 | DAFFE/CFA/WP1(93)6 | WP1 - CFA - OECD | - | En | - | Issues relating to the application and interpretation of paragraph 2 of article 15 of the model tax convention |
09/08/93 | DAFFE/CFA/WP1(93)5 | WP1 - CFA - OECD | - | En | K / 9 | The application of the model tax convention to partnerships, trusts and other non-corporate entities |
09/11/93 | DAFFE/CFA/WP1/M(93)2 | WP1 - CFA - OECD | - | En | V / 3 | Discussion concerning the application and interpretation of paragraph 2 of article 15 of the model tax convention document DAFFE/CFA/WP1(93)6 |
25/08/94 | DAFFE/CFA/WP1(93)6/REV2 | WP1 - CFA - OECD | - | En | - | 2nd Revision of the Issues relating to the application and interpretation of paragraph 2 of article 15 of the model tax convention; Document DAFFE/CFA/WP1(93)6 |
07/09/94 | DAFFE/CFA/WP1/MR(94)8 | WP1 - CFA - OECD | - | En | § / 6 | 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 | Benefits in kind; 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/M(94)2 | WP1 - CFA - OECD | - | En | V / 5 | Computation of the 183-day rule; discussion of the document DAFFE/CFA/WP1/MR(94)2/REV3 (The 1995 Update) |
08/11/94 | DAFFE/CFA/WP1(94)9 | WP1 - CFA - OECD | - | En | § / 9,18,38-40 | 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 | § / 5 | Preparing for the 1996 Update; Recommendations of the Steering Group |
30/06/95 | DAFFE/CFA/WP1(95)5/REV1 | WP1 - CFA - OECD | - | En | IB,IIB,C,D / 3,8-11 | 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 | IB,IIB,C,D / 4,11-17 | 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 | 50-53,102-105 / 6,11,12 | 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! | ID / 4 | Preparing for the 1995+update; The document contains issues which positive action is recommended and issues that should be closed without further action |
19/12/95 | DAFFE/CFA(95)16 | CFA - OECD | - | - | § / 9,22 | 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 | IC,IIA,B,IIIB / 4,9,17 | Place of Exercise of Employment under Article 15 and Issues carried forward for discussion in February 1996 ; Working party proposals for the 1995+ update to the model tax convention |
05/02/96 | DAFFE/CFA/WP1(96)5 | WP1 - CFA - OECD | - | En | 8,9,10 / 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 | IIA,B,IIIA,IVA / 9,15,16,23 | Proposals for the next update to the Model Tax Convention |
11/02/97 | DAFFE/CFA/WP1(97)6 | WP1 - CFA - OECD | - | En | B3 / 4 | Changes to the Commentary 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 | D / 5 | New proposals by the steering group; Place of activity of abstaining from work |
10/07/97 | DAFFE/CFA/WP1/M(97)1 | WP1 - CFA - OECD | - | En | VIA,b / 6 | Discussion of WP1 concerning the definition of “employer" and remuneration not “borne by” DAFFE/CFA/WP1(96)17, |
22/08/97 | DAFFE/CFA/WP1(97)14 | WP1 - CFA - OECD | - | En | IA,IIA / 4,5,6-10 | Remuneration not "borne by" a permanent establishment or fixed base, definition of "employer"; Proposals for the next update to the Model Tax Convention |