That sounds pretty horrible. Am I correct in assuming though that once you get over the five year hump, you're OK? Also wouldn't startups mostly be paying devs out of VC funding rather than revenue the first five years?
No, you never “catch up” unless you fire every software engineer (so income and trailing five years of amortization cancel out).
Year 5 is just a steady state of no more phantom profit taxes, but you never really get that extra tax you paid back if you want to keep operating at the same level or grow.
That makes sense, thanks for clarifying. How do you think businesses would react to this? For example, I imagine self-hosted servers would need to be depreciated too, so the tech community invented cloud as the solution. Maybe this policy change will cause tech companies to hire more TVCs rather than FTEs?
Contractor expenses to develop software are also R&D. As would cloud expenses for your test environment, probably. More likely, companies will engage in activities that are arguably not "software development," including things like maintaining existing software.
Presumably if a company doesn't build software in-house and "buys a product", then that's not R&D? Then, the companies making said "products" would be based in countries that don't have such draconian laws...