Bibliographic record
Abstract
An important recent development in international taxation is the publication of the OEEC (the forerunner of the OECD when it was a purely European organization, although representatives from the United States and Canada were also present at the discussions on tax treaties) archives on the development of tax treaties in a website http://www.taxtreatieshistory.org/ organized by the Institute for Austrian and International Tax Law, Vienna, IBFD, Universith Cattolica del Sacro Cuore, Piacenza, Italy, IFA Canadian Branch and the Canadian Tax Foundation. While this may sound like a rarefied topic, the OEEC period from 1956 to 1961 is the story of the making of the current OECD Model. Previously there was a gap in the published sources after the end of the League of Nations Mexico and London Models of 1943 and 1946, which suffered from the wartime domination by the South Americans of the Mexico Model, and the Europeans doing what they could in the London Model to reverse some of the worst excesses. By the time of the OEEC it was accepted that this was not the way of the future. After the London Model there was previously a complete gap in the history until the publication of the 1963 OECD Draft, which is essentially the OECD Model as we have it today. True there have been many changes in the meantime, particularly to the Commentary, but when compared to the whole edifice these are merely tinkering. The 1963 OECD Draft seemed to have arrived from nowhere and one wondered how this arose. Now, with the publication of the OEEC archives, we know. It was the work of (ultimately) 15 Working Parties (plus another dealing with estate taxes) of the Fiscal Committee each comprising delegates from two countries working on a separate article of the Model and reporting to the other countries at regular meetings of the Fiscal Committee. The results were most impressive and one can trace how the articles developed. The minutes are available as transcribed versions in English and French together with a pdf file of the original minutes so that, for example, alterations can be seen. A few of the current problems can be traced to the technique of working on each article separately with, for example, the definitions article being started late and not being published in any of the Fiscal Committee's four reports. In that respect the League of Nations method of working was superior. For example, the other income article, which is effectively the general rule that had come first in the original League of Nations drafts, appears at the end because Working Party 14 started much later. I believe that we still have a mutual agreement provision in the tie-breaker for individuals because that article was drafted before the mutual agreement article. In addition some of the less obvious overlaps were not considered.
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How this classification was reachedexpand
Full frame distilled prediction
Teacher imitationNot calibrated prevalence, not ground truth. Human validation pending. Learned from the 10,348 direct Codex labels and 10,348 direct Gemma labels. Candidate is the union of thresholded teacher heads; consensus is their intersection. These outputs are machine_predicted_unvalidated and are not human labels or direct frontier model labels.
Codex and Gemma teacher scores by category
| Category | Codex | Gemma |
|---|---|---|
| Metaresearch | 0.001 | 0.000 |
| Meta-epidemiology (narrow) | 0.000 | 0.000 |
| Meta-epidemiology (broad) | 0.000 | 0.000 |
| Bibliometrics | 0.000 | 0.000 |
| Science and technology studies | 0.000 | 0.000 |
| Scholarly communication | 0.000 | 0.000 |
| Open science | 0.000 | 0.000 |
| Research integrity | 0.000 | 0.000 |
| Insufficient payload (model declined to judge) | 0.002 | 0.000 |
Machine scores (provisional)
The two teacher heads of the student model, read on this work. A score orders the frame for review; it never asserts a category, and the validation status ships verbatim with every row.
Baseline scores from an immature model (maturity gate not passed, 7 training rounds). Scores rank; they never assert a category.
score_only:v0-immature-baseline · verbatim from the scoring run: score_only means the number may rank works, and no category label ships from itClassification
machine, unvalidatedMachine predicted; a candidate call from one teacher head, not a consensus.
How this classification was reached, model by model and score by score, is at the end of the page under "How this classification was reached".