Income/Franchise:
Pennsylvania DOR Addresses Corporate Income Tax Sourcing of Other than TPP and Services
Corporation Tax Bulletin 2024-01: Sourcing Sales Other Than Tangible Personal Property and Services, Pa. Dept. of Rev. (1/5/24). The Pennsylvania Department of Revenue (Department) issued a state corporate net income tax (CNIT) bulletin addressing its “interpretation of key terms and concepts necessary to properly apply the statutory rules for sourcing sales” pursuant to legislative changes enacted in 2022 [see H.B. 1342 / Act 53 (2022) and State Tax Matters, Issue 2022-8, for more details on this legislation], which among other tax law changes, modified the sales factor calculation used for CNIT apportionment purposes by sourcing receipts from certain intangible property (e.g., receipts from patents, royalties, franchise agreements, sales or exchanges of securities held for sale to customers in the ordinary course of business, and interest in connection with loans) using market-based sourcing rules rather than location of income-producing activity based on costs of performance for tax years beginning after December 31, 2022. The guidance also reflects and explains how certain income from intangibles may be excluded from the sales factor. Please contact us with any questions.
30 Rockefeller Plaza New York, NY 10112-0015 United States
About Deloitte Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited (“DTTL”), its global network of member firms, and their related entities (collectively, the “Deloitte organization”). DTTL (also referred to as “Deloitte Global”) and each of its member firms and related entities are legally separate and independent entities, which cannot obligate or bind each other in respect of third parties. DTTL and each DTTL member firm and related entity is liable only for its own acts and omissions, and not those of each other. DTTL does not provide services to clients. Please see www.deloitte.com/about to learn more.
Deloitte provides industry-leading audit and assurance, tax and legal, consulting, financial advisory, and risk advisory services to nearly 90% of the Fortune Global 500® and thousands of private companies. Our professionals deliver measurable and lasting results that help reinforce public trust in capital markets, enable clients to transform and thrive, and lead the way toward a stronger economy, a more equitable society and a sustainable world. Building on its 175-plus year history, Deloitte spans more than 150 countries and territories. Learn how Deloitte’s approximately 415,000 peopleworldwide make an impact that matters at www.deloitte.com.
