This thesis examines the issue of preventing the circumvention of permanent establishment rules in international tax law, in accordance with Action 7 of the OECD's 'Action Plan to Combat Base Erosion and Profit Shifting'. A secondary topic, relating to value added tax, concerns the loss of the right to deduct input tax due to a lack of business status. This thesis was written as part of the Bachelor of Arts programme in Tax Management at FH Campus Wien.