"The agency element of permanent establishment : the OECD Commentaries from the civil law view"

In 1993, Sidney Roberts authored a famous article in Intertax on agencies and permanent establishments regarding the OECD Commentaries from a civil law perspective. The article engendered much debate (for example, see Avery Jones et al., "Agents as Permanent Establishments under the OECD Model Tax Convention", European Taxation 5 (1993), pages 154 to 181). It was, however, very long and complex. This is an abstract of the article, which should serve both to refresh the debate and communicate the original concepts succinctly.