The original OECD Profit Attribution report relied on the AOA, with an additional conceptual stretch, to move assets and taxable income into the PE. That was an issue since most treaties do not adopt the AOA. The new report addresses this issue and states that the examples are governed by the AOA and that “the attribution of profits to a PE in any particular case will be governed by the applicable tax treaty.” The report states that “the examples should not be understood as representing the only appropriate approach to attributing profits to a PE.” This clarification is helpful.