We provide here a written summary of answers provided by the Department of Revenue to the committee at periodic question and answer sessions. 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 a specific fact situation may request a written letter ruling under 61 Pa. Code Section 3.3.
Q&A with the Pennsylvania Department of Revenue
With respect to Corporate Net Income and Personal Income taxes, does the Department follow the Operational Approach or the Transactional Approach, and how granular is the DOR’s analysis?
The DOR uses a transactional approach and will review all facts and circumstances when making decisions regarding sourcing and apportionment.