Date |
Document |
Institution |
MCC |
Or Lan |
§ / Pages |
Summary |
05/06/57 |
TFD/FC/15 |
WP5 - FC - OEEC |
BE, SE |
Fr |
- |
New Draft paragraph 1 |
03/07/57 |
FC/M(57)2 |
WP5 - FC - OEEC |
- |
Fr |
III/ 2 - 3 |
Amendments to the Draft Recommendation (FC/WP5(57)2) |
03/09/57 |
FC/WP6(57)1 |
WP6 - FC - OEEC |
FR, DE |
Fr |
I/ 1 |
Proposed amendments to the Draft Recommendation
(FC/WP5(57)2) |
06/01/58 |
FC/M(58)1 |
WP5/WP6 - FC - OEEC |
- |
Fr |
Annex II/ 10 |
The Committee approves the Draft Article in report
FC/WP6(57)1, and reviews report TFD/FC/29 |
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 |
28/08/58 |
FC/WP13(58)1 |
WP13 - FC - OEEC |
CH |
Fr |
- |
Report by WP13 on the taxation of capital, with a Draft
Article and Observations |
16/12/58 |
FC/M(58)5 |
FC - OEEC |
- |
Fr |
IX/ 10 |
Discussion on the allocation of taxing rights based on Report
FC/WP13(58)1 |
10/01/59 |
FC/WP13(59)1 |
WP13 - FC - OEEC |
CH |
Fr |
- |
Second report containing a new Draft Article and its
Commentary |
21/01/59 |
TFD/FC/54 |
WP13 - FC - OEEC |
CH |
Fr |
- |
Report with a revised Draft Article and its Commentary |
23/01/59 |
TFD/FC/55 |
WP13 - FC - OEEC |
CH |
Fr |
- |
Final Draft Article |
28/02/59 |
FC/M(59)1 |
FC - OEEC |
- |
Fr |
IV/ 11 |
Review of report FC/WP13(58)1 and adoption of the revised
Draft Article TDF/FC/55 |
03/03/59 |
FC(59)1 |
FC - OEEC |
- |
Fr |
- |
Draft Article, as already approved, submitted for adoption |
20/03/59 |
TFD/FC/61 |
FC - OEEC |
- |
Fr |
- |
Draft Article as resulted after the discussion of the Fiscal
Committee |
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 |
05/05/59 |
FC(59)1rev1 |
FC - OEEC |
- |
Fr |
- |
Final text of the Article with its Commentary |
15/05/59 |
FC/M(59)2 |
FC - OEEC |
- |
Fr |
III/ 9 |
Adoption of the Article in report FC(59)1 |
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 |
§/32-33 |
Article text revised |
21/02/63 |
FC(63)2 |
FC - OECD |
- |
En & Fr |
§ / 21 |
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 |
VI / 16 |
The use of the word "professional services" in Art.
6(4) and 22, and not "independent personal services". Not clear if
and what the distinction is, and if the choice of wording is deliberate. |
14/04/67 |
TFD/FC/214 |
FC - OECD |
- |
En |
§ / 43-44 |
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 |
§ / 10 |
Analysis of deviations from the 1963 Draft OECD Convention in
tax treaties protocols signed between 1 July 1963 and 31 July1966. |
21/07/67 |
TFD/FC/218 |
FC - OECD |
CA |
En & Fr |
§ / 52 |
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 |
AU CH |
En & Fr |
§ / 7 |
New WP30 comprising AU & CH formed for working on
Articles 2, 3, 6, 13, 22, and questions concerning partnerships (Art. 1). |
16/09/67 |
TFD/FC/222 |
FC - OECD |
- |
En |
§ / 82-83 |
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 |
§ / 121 |
Analysis of conformity with or deviation from 1963 Draft OECD
Model in protocols signed between 01/07/63 and 01/01/67. |
16/05/69 |
DAF/FC/69.8 |
FC - OECD |
- |
En |
167-169/118-121 |
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 |
241 / 175 |
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. |
27/06/69 |
FC/WP30(69)1 |
WP30 - FC - OECD |
AT CH |
En |
133-148 / 37-40 |
Considerations of WP30 pertaining to the 1963 Draft based on
observations of delegates of member countries and analyses of existing tax
treaties. |
29/12/69 |
DAF/FC/69.17 |
FC - OECD |
- |
En |
a-c / 5-6 |
Discussion of WP30's work on Article 22 of the 1963 OECD
Draft contained in FC/WP30(69)1 dt 27/06/69. |
04/06/70 |
FC(70)1 |
FC - OECD |
- |
En |
167-169 / 95-96 |
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 |
241 / 138 |
Analysis of deviations of protocols concluded amongst member
countries, between 01/07/63 and 01/01/69 from the 1963 OECD Draft. |
16/12/70 |
DAF/FC/7Q.14 |
FC - OECD |
- |
En |
C / 7 |
Proposals for the amendment of commentaries to Art. 22, which
were agreed to by the Fiscal Committee. |
17/06/71 |
CFA/WP1(71)3 |
WP1 - CFA - OECD |
- |
En & Fr |
§ / 6, 17-18 |
Latest version of Article and Commentaries. |
10/11/71 |
CFA(71)10 |
CFA - OECD |
- |
Fr & En |
§ / 8, 57-58 |
Revised text of Article and Commentary as unanimously
approved by the Fiscal Committee or by Working Party N° 1. |
07/01/72 |
CFA(71)10 (Corr) |
CFA - OECD |
- |
En & Fr |
D / 6 |
Corrigendum to the revised commentaries to Article 22 as
contained in CFA(71)10 dt 10/11/71, in order to harmonise it with the revised
commentaries on Article 8. |
10/02/72 |
CFA(71)10 (1st Revision) |
CFA - OECD |
- |
En & Fr |
§ / 9, 55-56 |
Revised text of Article and Commentary as adopted by WP1
during its 2nd session. Contents of CFA(71)10 dt 10/11/71 revised. |
12/09/75 |
CFA/WP1(75)5 |
WG15 - WP1 - CFA - OECD |
NL,JP,IE,CH |
En & Fr |
7 / 2,3 |
(The Double residence
Problem and possible solutions) Unsolved problems of elimination of double
taxation a continuation of the document CFA/WP1(74)2 |
30/10/75 |
DAF/CFA/WP1/75.14 |
WP1 - CFA - OECD |
- |
Fr |
A / 1 |
The amendment of the article as proposed by the Second Report
of Working Group Examination of the Second Report of Working Group No. 15 -
CFA/WP1(75)5 of 12th September, 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 |
§ / 101 |
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 |
- |
- |
§ / 46 |
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 |
- |
- |
§ / 30 |
Part 4: Reservations on the Articles |
01/03/77 |
CFA (76)7part2rev1 |
WP1 - CFA - OECD |
- |
Fr & En |
§ / 46 |
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 |
11/03/77 |
CFA(76)7part4rev1 |
WP1 - CFA - OECD |
- |
En & Fr |
§ / 22 |
1st revision and final version of Part 4 of the document
CFA(76)7: Reservations on the Articles |
07/10/77 |
DAF/CFA/WP1/77.12 |
WP1 - CFA - OECD |
US |
En |
18 / 19 |
The document contains the main differences between the OECD
and the United States Model Convention |
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/WP1/89.3rev1 |
WP1 - CFA - OECD |
- |
En |
§ / 43,44 |
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 |
§ / 44,45 |
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) |
23/08/95 |
DAFFE/CFA/WP1/WD(95)17 |
WP1 - CFA - OECD |
- |
En |
69-70 / 8 |
Changes to the OECD model tax convention and its commentaries
from 1977-1995 |
26/08/96 |
DAFFE/CFA/WP1/MR/M(96)1 |
WP1 - CFA - OECD |
- |
En |
D1 / 3,4 |
Discussion of the working party concerning the deletion of
the paragraphs 4.3 of the commentary |
26/08/96 |
DAFFE/CFA/WP1(96)17 |
WP1 - CFA - OECD |
- |
En |
IIID / 17 |
Proposals for the next 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 |
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