Symbols for Article 7

The general explanation of the symbols used is given in Meaning of Symbols. The specific notes relating to this article are:

This is an important article and deviations which are not merely drafting or very minor need to be noted. The differences between the 1963 and the 1977 texts are very minor, and compliance with 1963 generally therefore merits . The essential principle is that the business profits (industrial or commercial profits) of an enterprise of country A shall not be taxable in country B unless the enterprise carries on business in country B through a permanent establishment situated therein, and that the profits of such a business shall only be taxable in country B to the extent that they are attributable to that permanent establishment. Any deviation from this, eg the application of a force of attraction rule, will be symbolised by .

There may be additional notes on offshore oil and gas activities. These are in general reflected by , but qualify for if the reference is only to exclude such offshore activities from the article).

The overall picture of the extent to which countries follow the Model is shown in the Model Article 7 Summary.