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Taxing the Intangible: Overview of global approaches and a review of recent policy changes in the UK


This paper examines the current approaches to taxation of intangibles in three different jurisdictions: Australia, the US and the UK, with a primary focus on the UK. The first part of the paper outlines the economic impact of various intangible assets. It then outlines the accounting issues related to intangibles as a foundation to an overview of the current tax treatment of intangible assets and goodwill in the three jurisdictions largely built on these accounting principles. The paper then focuses on the recent changes to UK legislation for taxing intellectual property, goodwill and other intangibles. The paper illustrates that, whilst these changes were important, they by no means go as far as they may have gone, given existing knowledge in the area and even the apparent desires of the policy makers in proposing the tax reform in this area. It however, illustrates a promising trend in the process of tax reform debate.

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.
David was, until recently, a researcher and postgraduate student at the University of Birmingham Business School. He is currently completing his professional tax examinations in the UK with KPMG.
Current at 25 August 2003

Andrew LYMER
Andrew is a Senior Lecturer in Taxation and Information Systems at the University of Birmingham Business School in the UK. His research work relates to international taxation, and to the role of IT and information systems in business, with a particular focus on the impact and influence of the Internet.
Current at 25 August 2003

Gary is the Pricewaterhouse Coopers Term Professor in the Fisher School of Accounting at the University of Florida and the director of its accounting PhD program.
Current at 25 August 2003
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