Clifford Chance

One Big Beautiful Bill Act - The impact on the clean energy production tax credit and investment tax credit

21 July 2025

In On July 4, 2025, President Trump signed into law the One Big Beautiful Bill Act(the OBBBA), which significantly curtails and, in some cases, terminates, clean energy tax incentives introduced or expanded under the Inflation Reduction Act of 2022 (the IRA). This includes the clean electricity production credit under Section 45Y (the PTC) of the Internal Revenue Code of 1986 (the Code) and the clean electricity investment credit under Section 48E of the Code (the ITC). The OBBBA also expands upon the existing foreign entity of concern (FEOC) rules under the IRA by imposing new "prohibited foreign entity" restrictions on U.S. taxpayers and qualified facilities.

Below is a summary of the notable provisions in sections 70512 and 70513 of the OBBBA, which relate to the ITC and PTC. The Clifford Chance team will continue to monitor any guidance or executive orders as they are published.

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