Maaaaybe, but I've seen what a few companies count as R&D and I wouldn't be so sure. I work in a pretty traditional SwE role, not at a pharma company (I bailed on Chem long ago when I saw the salaries). By my reckoning none of what we do should be categorized as R&D, but for tax purposes almost all of it is. Both SwE hours and lawyer hours (we have a resident lawyer). It's pretty obvious when the accountants go fishing for excuses and they always seem to be able to find them.

Whenever I hear about a pharma company getting held accountable, it's for even more egregious violations (put a token lab in every building now it's all R&D wheee).

Point is: I have my doubts.