For purposes of this section, any amount paid or incurred in connection with the development of any software shall be treated as a research or experimental expenditure.

I wonder what this section and any software means

It means before you may have had to justify whether software development qualified as R&E, now you don’t. It unambiguously qualifies, if you’re claiming it as R&E. And unlike before, R&E must now be amortized.

But AFAIK you don’t need to claim it as R&E. That everyone has to claim all software development as “research and experimental expenditure” seems completely unfounded and a misunderstanding.

I assume there were-are other benefits claiming software development as R&D/E - and that the vast majority of it probably shouldn’t.

Yup. Exactly. And from that perspective this is actually a good thing, because now you don’t have to worry about whether software development qualifies as R&E.