How does a sperm find its way? The study of guidance cues has fascinated sperm biologists and in particular the prospect of rheotaxis, that is a fluid flow orienting the direction of sperm swimming, has been the subject of extensive recent study, as readily motivated by the prospect that such guidance may be active in the mammalian female reproductive tract. For instance, it has been hypothesized that helical sperm flagellar beating is necessary for such guidance, whereas there is an extensive diversity of flagellar beating patterns, with planar sperm beating readily observed in human cells for example. In particular, such cells will not be guided by fluid flow according to hypothesized mechanisms for rheotaxis presented thus far. Here, using simulation methods, we investigate rheotaxis for a wide range of flagellar beat patterns. Providing the virtual sperm firstly does not possess a tightly circling trajectory in the absence of a background flow and secondly, remains within a region of low shear to prevent being washed away by the background flow, rheotaxis is generally observed with the sperm swimming into the flow together with a possible transverse velocity. Tight circling sperm motility, as observed in select hyperactivated sperm and CatSper mutants, is predicted to disrupt the rheotactic response, whereas confinement to low shear regions generally requires boundary accumulation, thus introducing subtleties in the relationship between rheotactic behaviours and the flagellar waveform and sperm characteristics. Nonetheless, such predictions suggest such rheotactic guidance may be more common and robust than previously thought, and we document simple criteria for the presence of rheotaxis that are consistent with our simulations and understanding, as well as reported observations to date.