How OBBBA tax changes affect energy companies

What it means for energy companies

The One Big Beautiful Bill Act (OBBBA) makes 100% bonus depreciation permanent, giving oil and gas and utilities companies a powerful way to recover the cost of capital investments faster.

For oil and gas companies, this means they can immediately deduct the cost of qualifying assets, such as rigs, well equipment, pipelines, and processing facilities—freeing up cash that can be reinvested in growth. Whether upstream, midstream, or downstream, the ability to expense these assets in the year placed in service improves returns and supports long-term investment strategies.

For utilities companies, the benefits go beyond tax savings. Utilities typically operate under tight regulations and long asset lifecycles, which can make financial planning complex. Bonus depreciation helps utilities better align tax outcomes with their capital plans, reduce balance sheet pressure, and simplify financial modeling. This added flexibility makes it easier to evaluate and fund major initiatives like grid modernization, renewable energy integration, and reliability upgrades.

What it means for energy companies

This change gives capital-intensive energy companies more breathing room to finance growth. For upstream oil and gas operators, it allows greater deductibility of interest tied to activities such as exploration and production—which is especially valuable in periods of commodity price volatility when cash flow is unpredictable.

Midstream and downstream players benefit too, as pipeline expansions, storage infrastructure, and refining upgrades often rely on debt financing. With more interest deductible now, companies can better manage and optimize their capital structure with fewer tax inefficiencies.

Utilities companies, which often carry substantial debt to fund long-term infrastructure projects, gain a clearer path to aligning financing with regulatory and operational goals. Reverting to the EBITDA-based limitation reduces the risk of disallowed interest deductions that could otherwise distort rate-setting models or complicate cost recovery.

This change also simplifies modeling for utilities that operate under multi-year capital plans, making it easier to forecast tax impacts and evaluate financing options for grid modernization, clean energy integration and reliability upgrades.

What it means for energy companies

Full expensing for domestic R&D costs gives energy companies a direct incentive to invest in innovation. For oil and gas businesses, this means they can immediately deduct costs tied to initiatives such as developing new drilling technologies, enhanced recovery methods, and emissions-reduction solutions.

That upfront deduction improves ROI and frees up capital for further innovation—which could be especially valuable for smaller operators and service providers that often face cash constraints but play a critical role in advancing industry capabilities. It also supports pilot projects and partnerships with universities or startups, which are increasingly common in the sector.

Utilities companies stand to benefit as well, particularly those focused on smart grid technologies, energy storage, and customer-facing digital platforms. Full expensing helps utilities justify R&D investments that improve system efficiency, reliability and customer engagement. It also supports collaboration with startups, as utilities seek to pilot new solutions in areas like demand response, distributed energy resources, and cybersecurity. 

What it means for energy companies

The equalization of credit rates for EOR and utilization with secure geological storage makes carbon capture more financially viable for oil and gas producers.

Previously, the lower EOR rate created a disincentive for companies to pursue carbon utilization strategies. Now, with parity in credit value, producers can integrate carbon capture into EOR operations without reduced tax benefits. This shift may support broader sustainability goals while helping companies monetize emissions-reduction technologies already embedded in their operations.

Utility companies, especially those operating fossil-fuel-based generation assets, gain a clearer path to decarbonization. The updated credit amounts and streamlined rules reduce uncertainty around project economics and compliance, making it easier to justify investments in carbon capture retrofits. 

What it means for energy companies

For oil and gas companies with downstream operations or renewable fuel investments, these changes shape a tighter but more predictable credit environment. The extension of the section 45Z credit for two additional years provides significant benefits to these producers.

Producers sourcing feedstocks in the U.S., Canada, or Mexico will continue to benefit, but those relying on global supply chains may need to reassess their strategies once the rules are effective in 2026.

The elimination of the higher credit for sustainable aviation fuel (SAF) may disincentivize some projects from being developed.

With respect to section 45V clean hydrogen projects, project developers must take due care to document the commencement of construction in order to ensure that their project is safe-harbored. Both the physical work test and 5% safe harbor are available despite certain changes being made recently by executive order and IRS guidance for wind and solar projects.

What it means for energy companies

By aligning IDC treatment under the AMT with regular tax rules, the OBBBA removes a major source of uncertainty for oil and gas companies.

IDCs—such as labor, site preparation, and drilling services—represent a significant portion of exploration and development costs. Without this alignment, companies could have faced higher AMT liabilities even when their regular tax position was optimized. Now, with consistent treatment, companies can confidently model their tax exposure and make drilling decisions based on operational and market factors, not tax distortions.

What it means for energy companies

This provision encourages more active participation in the energy startup ecosystem and may influence how corporate venture capital teams evaluate opportunities.

The expanded QSBS exclusion may offer a compelling incentive for early-stage investment in energy innovation. Oil and gas companies with venture arms or incubators can now realize greater tax benefits when backing startups focused on projects such as clean tech, digital oilfield solutions or emissions monitoring.

The tiered exclusion structure rewards longer holding periods, aligning well with the typical investment horizon in energy technology. The increased per-issuer cap and asset threshold also broaden the pool of qualifying companies, making it easier to structure tax-efficient exits.

Utilities companies exploring strategic investments such as grid tech, energy storage or customer-facing platforms can also benefit. By targeting QSBS-eligible startups, utilities can support innovation while enhancing the after-tax return on investment. 

What it means for energy companies

Rebranding and recalibrating FDII and GILTI to FDDEI and NCTI, respectively, signal a continued push to keep profits and innovation anchored in the U.S. While the reforms aim to preserve U.S. competitiveness, they also reinforce the need for proactive international tax planning.

For global oil and gas companies, the removal of the tangible income return deduction, combined with reduced deduction rates, could result in higher effective tax rates, especially for those with significant offshore investments in tangible assets.

The elimination of this deduction removes a key tax benefit that previously supported tangible asset investment abroad, prompting companies to reevaluate the tax impact of foreign earnings and investments.

What it means for energy companies

While not a direct tax provision, these changes influence the broader energy landscape and reinforce the importance of integrating tax, regulatory and operational strategies.

The rollback of royalty rate increases and the repeal of the methane royalty provide immediate cost relief for oil and gas producers operating on federal lands. These changes restore predictability to lease economics and may improve the viability of marginal projects that were previously burdened by higher fees.

The mandated frequency of lease sales and limits on new requirements also reduce regulatory uncertainty, giving companies more confidence to plan and invest in federal acreage. For upstream operators, this could translate into more aggressive bidding strategies and expanded drilling programs.

Utilities companies that rely on natural gas from federal lands—either directly or through suppliers—may benefit indirectly from increased production and stabilized pricing. The more predictable leasing environment also supports long-term fuel procurement planning, especially for utilities with gas-fired generation assets.