As one of its primary goals, the BEPS program set out to address international tax planning. These designs make use of, among other things, the provisions set forth in the tax treaty for the goal of reaping benefits and tax reliefs that erode nations' tax bases.

The BEPS method defines inappropriate exploitation or misuse of a tax treaty as the application of the provisions stated in the treaty to seek relief or advantages in a way that the parties to the treaty did not intend ("treaty abuse"). Arranging or entering a transaction with the primary goal of obtaining benefits under a tax treaty is also termed inappropriate exploitation of a tax treaty. One of how the BEPS program has taken to deal with the abuse of art is by establishing a general anti-planning provision whereby treaty benefits can be avoided in those cases where one of the administrative purposes for which a structure or transaction is created. Done for tax relief.