Date |
Document Nr. |
Institution |
MCC |
Or Lan |
§ / Pages |
Summary |
|
|
|
|
|
|
|
16/12/58 |
FC/M(58)5 |
FC - OEEC |
|
Fr |
III/ 6 |
Creation of WP15 |
|
02/03/59 |
FC/WP15(59)1 Part I |
WP15 - FC - OEEC |
DK, IR |
En |
|
Extensive report containing an in-depth analysis, examples of
similar clauses from existing tax agreements and a Draft Article |
|
02/03/59 |
FC/WP15(59)1 Part II |
WP15 - FC - OEEC |
DK, IR |
En |
|
Annex to the first part of the report containing historical
documents and similar clauses from existing tax agreements |
|
14/03/59 |
TFD/FC/58 |
FC - OEEC |
NL |
En |
|
Position of the Dutch Delegation on the methods for the
avoidance of double taxation |
|
13/05/59 |
FC/WP15(59)2 |
WP15 - FC - OEEC |
DK, IR |
En |
|
New Draft Article with explanatory notes; in the Annex a Draft
Article from the UK is provided |
|
15/05/59 |
FC/M(59)2 |
FC - OEEC |
|
Fr |
II/ 5 |
Discussion including different views from various Member
Countries on report FC/WP15(59)1 |
|
30/12/59 |
FC/M(59)5 |
FC - OEEC |
|
Fr |
II/ 4 |
Extensive discussion on Memorandum FC/WP15(59)2 |
|
25/04/60 |
FC/WP15(60)1 |
WP15 - FC - OEEC |
DK, IR |
En |
|
New extensive report including a Draft Article and explanatory
notes |
|
28/05/60 |
FC/M(60)3 |
FC - OEEC |
|
Fr |
II/ 4 |
Examination of report FC/WP15(60)1 |
|
28/09/60 |
FC/WP15(60)2 |
WP15 - FC - OEEC |
DK, IR |
En |
|
Final report containing a new Draft Article and its Commentary |
|
10/04/61 |
TFD/FC/117 |
FC - OEEC |
CH |
Fr |
|
Alternative Draft Article from the Swiss Delegation |
|
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 |
VI/ 7 |
Discussion on report FC/WP15(60)2 and on the proposals
submitted; adoption of the Article and its Commentary |
|
08/06/61 |
TFD/FC/128 |
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 |
|
07/03/62 |
TFD/FC/143 |
|
JP |
- |
- |
Memorandum of Japanese government on tax sparing |
|
21/02/63 |
FC(63)2 |
FC - OECD |
- |
En & Fr |
§ / 22 |
Latest draft model convention. |
|
08/09/64 |
TFD/FC/173 |
FC - OECD |
JP |
En |
§ / 8 |
Questions by the Japanese Delegation concerning the 1963 Draft
OECD Model. |
|
14/04/67 |
TFD/FC/214 |
FC - OECD |
- |
En |
§ / 45-46 |
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 |
§ / 10-11 |
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 CH |
En & Fr |
§ / 27-28 |
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 CH DE |
En & Fr |
§ / 53- 54 |
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. |
|
16/09/67 |
TFD/FC/222 |
FC - OECD |
- |
En |
§ / 84-85 |
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 |
170-171/122-125 |
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 |
242 / 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. |
|
04/06/70 |
FC(70)1 |
FC - OECD |
- |
En |
170-171 / 97-99 |
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 |
242 / 138 |
Analysis of deviations of protocols concluded amongst member
countries, between 01/07/63 and 01/01/69 from the 1963 OECD Draft. |
|
01/03/73 |
DAF/CFA/2584 |
WP1 - CFA - OECD |
|
Fr |
26 / 8 |
(Non- Discrimination of
PE) Credit for foreign tax |
|
15/09/73 |
CFA/VP1(73)9 |
WG30 - WP1 - CFA - OECD |
AT BE CH |
Fr |
17 / 5 |
Is Article 23 applied to the total income (in the hands of the
partnership or of all the partners), or is it applied solely to resident
partners? |
|
28/02/74 |
CFA/WP1(74)2 |
WG15 - WP1 - CFA - OECD |
NL,JP,IE,CH |
En |
|
Whether the Model Draft Convention gives sufficient rules for
the taxation and the relief in respect of income from Contracting State (R)
or from a third State (S), such as income from immovable property, dividends,
interest or royalties, attributed to a permanent establishment or fixed base
which a resident of one Contracting State (R) has in the other Contracting
State (P). |
|
26/02/75 |
DAF/CFA/WP1/75.8 |
WP1 - CFA - OECD |
|
Fr |
|
Examination of the first report of Working Group No. 15 -
CFA/WP1(74)2 of 28th February, 1974 |
|
13/03/75 |
DAF/CFA/WP1/75.7 |
WP1 - CFA - OECD |
|
Fr |
4 / 1 |
The rapporteur would submit a revised report in the autumn
which would take account of the discussions and he would propose new texts
for Article 23 and the Commentary thereon. |
|
18/03/75 |
CFA/WP1(74)2 (Add) |
WG15 - WP1 - CFA - OECD |
NL,JP,IE,CH |
- |
|
Addendum to the first report on Articles 23A and 23B
(CFA/WP1(74)2) of February 28, 1974 concerning the double residence |
|
17/06/75 |
DAF/CFA/WP1/75.10 |
WP1 - CFA - OECD |
|
Fr |
2 / 1 |
The Rapporteur would draw up a revised report of the Addendum
to CFA/WP1(74)2 of 18th March, 1975] for discussion by the Working Party at
its meeting in October 1975. |
|
12/09/75 |
CFA/WP1(75)5 |
WG15 - WP1 - CFA - OECD |
NL,JP,IE,CH |
En & Fr |
|
Unsolved problems of elimination of double taxation a
continuation of the document CFA/WP1(74)2. This second part contains the
proposals changes in the Articles, and
the Commentaries. |
|
30/10/75 |
DAF/CFA/WP1/75.14 |
WP1 - CFA - OECD |
|
Fr |
|
Examination of the Second Report of Working Group Examination
of the Second Report of Working Group No. 15 - CFA/WP1(75)5 of 12th
September, 1975 |
|
16/01/76 |
CFA/WP1(76)1 |
WG15 - WP1 - CFA - OECD |
NL,JP,IE,CH |
En |
|
Third report that contains the revised versions of the text of
the Articles and of the Commentary; however, not including Commentary on
Article 23B. |
|
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) |
|
08/03/76 |
CFA/WP1(76)4 |
WG15 - WP1 - CFA - OECD |
NL,JP,IE,CH |
En & Fr |
|
Full version of the revised texts of Articles 23A and 23B of the OECD Draft Convention and of the
Commentary thereon |
|
05/11/76 |
DAF/CFA/WP1/76.19 |
WP1 - CFA - OECD |
|
En & Fr |
§ / 103 |
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 |
|
- |
§ / 50 |
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 |
|
- |
§ / 32 |
Part 4: Reservations on the Articles |
|
01/03/77 |
CFA (76)7part2rev1 |
WP1 - CFA - OECD |
|
Fr & En |
§ / 50 |
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 |
|
07/10/77 |
DAF/CFA/WP1/77.12 |
WP1 - CFA - OECD |
US |
En |
III / 20 |
The document contains the main differences between the OECD
and the United States Model Convention |
|
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 |
|
|
21/07/88 |
DAFFE/CFA/WP1/88.7 |
WP1 - CFA - OECD |
|
Fr |
|
Report on the provisions of the 1977 MC which should be reviewed |
|
|
23/08/95 |
DAFFE/CFA/WP1/WD(95)17 |
WP1 - CFA - OECD |
|
En |
71-73 / 8 |
Changes to the OECD Model Tax Convention and its commentaries
from 1977-1995 |
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