Q&A with the Pennsylvania Department of Revenue

What factors are considered when auditing and assessing tax on intercompany transactions with holding companies?

Nov 04, 2015
The Department reviews the facts and documentation for each case to determine if there is economic substance to the transactions and whether the transactions are conducted with arm’s length rates and terms.

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Disclaimer

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.