This article analyses the three policy approaches to tax treaty entitlement that can be drawn from the new provisions introduced into the
OECD Model (2017): the structural approach, the analytic approach and the syncretic approach. The article specifically describes the OECD
Model and Commentary (2017). The analysis reveals important aspects of the impact of BEPS on tax treaties, notably that there are new
limitations on treaty entitlement in addition to a general ban on double treaty exemption.