This final Report, which includes Parts I-IV, provides the views of the Committee as to how the profits attributable to a permanent establishment should be determined. It replaces all previous drafts of the various Parts, which should no longer be considered to reflect the views of the Committee. There is a broad consensus among OECD countries that the conclusions reflected in this Report represent a better approach to attributing profits to permanent establishments than has previously been available. The Committee recognises, however, that there are differences between some of these conclusions and the practices and historical interpretation of Article 7 (as it has read since its last amendment in 1977) that were reflected in the Commentary on Article 7 as it read before the adoption of this Report (i.e. as most recently published as part of the 2005 OECD Model Tax Convention). For reference purposes, the current text of Article 7, as well as the Commentary thereon most recently published as part of the 2005 OECD Model Tax Convention, is included in the Appendix to this Report.