Q&A with the Pennsylvania Department of Revenue

For CNI Tax and CS/FF Tax apportionment purposes, is the sale or licensing of canned software delivered electronically treated as the sale of tangible personal property or the sale/licensing of intangible property?

Jun 30, 2011
The sale or licensing of canned software is the sale of tangible personal property.

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These documents provide a summary of the answers provided by the Department of Revenue to the PICPA Committee on State Taxation at its annual question and answer session. These documents are classified as revenue information issued for informational purposes only for the convenience of PICPA members. Pursuant to 61 Pa. Code Section 3.4, these documents should not be relied upon for any purpose or used in tax appeals. Taxpayers requiring a binding opinion on their specific fact situation may request a written letter ruling under 61 Pa. Code Section 3.3.