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Does the 15-year period for non-US developers only apply to developers? What about roles like designers, product managers, and so on?

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The technical qualification is "everything that qualifies as research and development"

I have this image in my head that R&D is some boffins in the back room inventing a something new, and then expanding on that idea is execution.

But "and development" covers everything we do in software development. Whether you fix a bug or write some documentation you are developing the product in some small way.

I imagine some business will need to restructure so the US arm is paying a service contract to use the software, and the foreign arm will own and develop the software.

Every year I have to gather documents as evidence of our R&D. The distinction from the accountants was that anything that was not BAU counted. So fixing a bug and supporting a production system did not count but developing a new feature would count.

I think your accounts are running a risk. Fixing a bug is really just "finishing" previous development work. Where do you draw the line. Which is a bug, a button that does something wrong; a button that does nothing; or a missing button?

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