Whatever the PPT’s ultimate effect, the test will not dramatically reshape international taxation schemes. IntroductionThe early 2010s represent perhaps the only time period in which international tax policy regularly filled the pages of the world’s largest newspapers. However, a contextualized approach to predicting the PPT’s effects suggests that commentators have overstated the test’s ultimate impact. Part I provides background on international tax policy, highlighting recent G20/OECD initiatives to change key elements of the international tax system. The Conclusion drives home this Note’s central thesis: viewed in proper context, the PPT may ultimately not be the “atomic bomb” of international tax.

Source: Washington Post March 26, 2026 00:56 UTC