In accordance with the action plan on base erosion and profit shifting (BEPS) the OECD has issued a discussion draft dealing with ways to prevent the abuse of tax treaties. The OECD is considering the development of new provisions in the OECD Model and recommendations on the design of domestic tax rules to make sure that treaty benefits are only granted where they are appropriate. Double non-taxation is not the intended outcome of tax treaty provisions and this will be clearly stated. The OECD will put forward policy issues that countries need to consider before they begin to negotiate a double tax treaty.