{"id":3013,"date":"2025-10-02T14:16:00","date_gmt":"2025-10-02T14:16:00","guid":{"rendered":"https:\/\/gtmtax.com\/?post_type=insight&p=3013"},"modified":"2026-01-15T14:26:05","modified_gmt":"2026-01-15T14:26:05","slug":"international-tax-implications-of-the-one-big-beautiful-bill","status":"publish","type":"insight","link":"https:\/\/gtmtax.com\/insight\/international-tax-implications-of-the-one-big-beautiful-bill\/","title":{"rendered":"International Tax Implications of the One Big Beautiful Bill"},"content":{"rendered":"
\n\n\n\n\n
\n
\n

On September 25, some of the world’s top tax professionals gathered for a day of thought leadership and discussion on the evolving complexities of international tax law. The one-day summit, FUSION 2025, featured panelists from three different continents and seven countries \u2014 covering topics such as Pillar 2 updates, the impact of global trade wars, and trends among auditors in various regions of the world.\u00a0 <\/em><\/p>\n

Below, we\u2019re sharing some insights from a panel discussion focused on the One Big Beautiful Bill Act (OB3), a tax reform package passed by the U.S. Congress on July 4, 2025. The panelists for this session were Andrew McKinley, Managing Director at GTM; Thomas Sch\u00e4nzle, an International Tax Partner at WTS Global (Germany); Eugene Lim, a Founding Principal of Taxise Asia (Singapore); and Ahmed El Jilali, a Tax Partner at Tiberghien (Belgium).<\/p>\n

OBBB Overview: Research and Experimental Costs <\/strong><\/h4>\n

In the United States, the tax code has typically allowed taxpayers to deduct research and development expenses from their taxable income. However, in 2017, during the first Trump administration, R&D deductions faced new restrictions. Instead of receiving all of the tax benefits immediately from these investments, filers had to follow an amortization schedule: domestic R&D had to be amortized over a five-year period, and foreign R&D over a 15-year period.<\/p>\n

OB3 lifted the amortization period for domestic investments, but kept it for foreign ones \u2014 a policy aimed at encouraging international companies to invest in R&D within the United States. While it may seem like a straightforward change, it will have ripple effects for many taxpayers. For example, these rules could impact a company\u2019s ability to claim other tax benefits due to changes in its taxable income limit.<\/p>\n

Belgium\u2019s R&D Tax Incentives: A Global Magnet for Innovation<\/strong><\/h4>\n

Belgium may be small in size, but it\u2019s managed to attract a wealth of research and development activity in recent years. The country has strategically offered generous tax incentives designed to draw foreign R&D centers, much like OB3 is designed to do. Ahmed El Jilali of Tiberghien outlined some of the comparisons between Belgium\u2019s tax policies and what\u2019s now changing in the United States:<\/p>\n