1. INTRODUCTION Tax laws (both domestic as also international) have been battling to counter tax treaty abuse. The structure of tax regimes created opportunities for Base Erosion and Profit Shifting (“BEPS”). BEPS represents tax avoidance strategies that taxpayers use, to shift their profits from high tax jurisdictions to low tax jurisdictions. Tax treaty abuse connotes availing treaty benefits in inappropriate circumstances and unintended manner. This undermines tax sovereignty. The treaty abuse deprives countries of its legitimate tax revenues. The geographical spread of such abuse suggests that every bilateral treaty is not subject to abusive exploitation. Empirically, only a few treaties are the chosen ones. Within such treaties, the smog of abuse does not engulf the entire treaty regime. Only a few selected (and often preferred) provisions which are (mis)used. Thu.......