After 5 years dont you end up with some "finished" R&D project that then can be later amortized, over say next 3 (or 5 years), so you reduce your tax base by those 2 million later on?
After 5 years the first years salaries are considered to be a "finished" R&D project, which means there's nothing left to amortize.
The only thing like that is that if, after a few years, you fire all your devs (or at least, all devs working on adding new features and building new products), then you can keep amortizing the last 4 years of salaries for your now-fired workers over the next few years, which reduces your tax base. But I mean, by that point, who cares? Any software business that has fired all its devs is over.
Doesn't help; what matters is your total R&D spend which - apparently according to current guidance - includes all/most of programmer salaries.
If you spend is going up, you're pre-paying more and more tax on profits you haven't earned yet. If your spend is constant, you'll stay the same amount behind. If your spend declines you'll start to catch up, and if it drops to 0 and stays there for ~4 years you'll catch up to where you would have been without the law change...but if you start spending again you have to start pre-paying again.
