And they don't consider "art" as R&D, for good or for ill, so at the end most of the time only innovative game engine development ends up falling under the umbrella.
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Similar provisions in the Swe tax code as the French, but regardless the winners are the big players that can pay for tax accountants that know how to wiggle it.
From a nationalist perspective, the US is really tripping themselves up by hurting the big player that’s given them a dominant position.
In France the issue is not so much the accountant work than building a good project argumentation that will convince an academic researcher that you are doing something interesting. Can be easy or very difficult depending on the background of the team.
But to be completely honest, if your studio is really doing something technologically innovative, it's not going to be hard to write a compelling case for it. And a 30% tax credit on R&D costs can make a difference for small teams. when it does not make sense... there are grants for art too.
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From a nationalist perspective, the US is really tripping themselves up by hurting the big player that’s given them a dominant position.