Q&A with the Pennsylvania Department of Revenue

With respect to Corporate Net Income Tax, does the DOR consider the provision of software in the “Cloud” a sale of TPP for CNIT purposes?

Nov 04, 2015
Additional details would be needed to provide specific guidance to this question.  The Department would however generally conclude that, as a result of the sourcing changes in Act 52 of 2013, the sale would be sourced to Pennsylvania to the extent the delivery occurs in Pennsylvania whether the sale is determined to involve TPP (e.g. canned software) or a service.




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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.