The BEPS project addresses forms of tax treaty abuse consisting of arrangements that “erode” the tax base or that avoid tax through profit shifting, hence “Base Erosion and Profit Shifting” (BEPS). To this end, the OECD issued a Discussion Draft on 14 March on Preventing the Granting of Treaty Benefits in Inappropriate Circumstances. The Draft proposes to deal with the problem by means of a new combined test for eligibility for treaty benefits, consisting of a “limitation on