The contrast between “form” and “substance” will be discussed with respect to intangible assets, by analyzing some specific rules: the amortization regime according to the Italian Income Tax Act, the International Accounting Standards treatment and the OECD Base Erosion and Profit Shifting Report which expressly involve intangible treatment.

The path leads to verify the coexistence of many different concepts of substance and to test if legislative and academic references to “economic substance” are meaningful.