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Boosting the knowledge economy: the role of taxation in businesses’ choice of location of intangible property


Intangible property has become a key aspect of the modern economy with increasing focus by the Organisation for Economic Development (OECD) and national regulators on the value stored in such assets. The changes to the identification and taxation of intangible property in the United Kingdom 2002 Finance Bill were said to be needed in order to clear up the confused and ad hoc rules applicable to intangibles. The Regulatory Impact Statement that accompanied the changes in Schedule 29 indicated inter alia that “[w]ithout reform, the UK would continue to treat intangible assets less favourably than many other countries to the disadvantage of companies based here.” The changes were welcomed and, despite early amendments required to deal with unforeseen consequences of the changes, appear to have been effective in improving the coherence and simplicity of the taxation of intangibles. This article questions whether the reforms have made the UK a more attractive place to do business using intangibles.

Author profiles:

Author Photo - Michael Walpole CTA
Prof Michael Walpole CTA

Professor Michael Walpole is the Associate Head of School (Research) at the School of Taxation and Business Law (including Atax) in the Australian School of Business.

Michael has a PhD in Taxation Law from the Faculty of Law UNSW. Prior to academic life, Michael worked as a Tax Consultant with Ernst & Young, and prior to that he was in private practice as a legal practitioner. As a partner in a small firm, Michael's legal practice was extremely varied. As an academic he has been awarded the Hill Medal by the Australasian Tax Teachers Association (ATTA) for his contribution to tax teaching and is a past President of ATTA.

Michael has authored and co-authored several books including Proposals for the Reform of the Taxation of Goodwill, Understanding Taxation Law and Compliance Cost Control. Michael has also written and presented many papers on his research topics to practitioner and academic audiences in Australia and overseas. He is co-editor of the Australian Tax Review and he is also author and co-author of a number of articles on GST, taxation of intellectual property, tax administration and taxation compliance costs, especially psychological costs of taxation compliance.

Michael is an International Research Fellow at the Oxford University Centre for Business Tax in the Said Business School, University of Oxford.

Current at 31 October 2013 Click here to expand/collapse more articles by Michael WALPOLE.
Shirley CARLON
Corresponding author, Senior Lecturer, School of Taxation and Business Law, UNSW
Current at September 2013
Click here to expand/collapse more articles by Shirley CARLON.
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