Are service fees earned by a Florida company from a foreign related customer sourced to Florida?

Plain-English summary

The Florida Department of Revenue ruled that fees earned by a Florida company for business-support services supplied to a foreign related entity were not Florida sales. The taxpayer performed redacted support functions for an international group and charged its foreign parent on a cost-plus basis.

The Department treated the customer's purchase of the services as the income-producing activity. Under its analysis, the activity occurred where the customer was physically located. Because the customer was outside Florida, none of the service fees at issue entered the Florida sales-factor numerator.

The TAA said the same rule would source receipts to Florida when the customer was physically located in Florida, for years in which the taxpayer was entitled to apportion income.

What this means for you

International corporate groups

Related-party status did not change the location analysis. Document the contracting customer's physical location and the services it purchases.

Transfer-pricing and tax teams

The taxpayer had a third-party transfer-pricing study and a formal services agreement, but sourcing still turned on the customer's location under the ruling.

Accountants and tax professionals

The service descriptions are substantially redacted. Use the TAA for its customer-location rule, not as proof that every internationally delivered support service receives the same treatment.

Common questions

Q: Were services performed by the Florida taxpayer automatically Florida sales?
A: No. The Department sourced the receipts to the customer's physical location.

Q: Where was the customer?
A: Outside Florida, so the fees at issue were not Florida sales.

Q: What if the customer were in Florida?
A: The ruling says the receipts would be Florida sales.

Q: Did the TAA decide whether the taxpayer could apportion?
A: It stated the sourcing rule for tax years when the taxpayer was permitted to apportion.

Citations and references

• Fla. Stat. §§ 220.15 and 213.22
• Fla. Admin. Code rr. 12C-1.0153, 12C-1.0154, and 12C-1.0155(2)(l)

Source

• Landing page: Florida Tax Law Library
• Advisement: TAA 18C1-007

Original ruling text

QUESTION: HOW SHOULD TAXPAYER’S SALES GENERATED FROM THE PROVISION OF SERVICES
TO RELATED ENTITIES OPERATING INTERNATIONALLY BE SOURCED?
ANSWER: PURSUANT TO RULE 12C-1.0155(2)(L), F.A.C., WHEN THE ACTIVITY PRODUCING THE
SALES REVENUE OCCURS ENTIRELY IN FLORIDA, THE RECEIPTS FROM THE FLORIDA ACTIVITY
ARE DEEMED TO BE FLORIDA SALES. THE INCOME PRODUCING ACTIVITY OCCURS ENTIRELY IN
FLORIDA WHEN TAXPAYER’S CUSTOMER IS PHYSICALLY LOCATED IN FLORIDA.

June 4, 2018
XXXXX
XXXXX
XXXXX
XXXXX
Re: Technical Assistance Advisement – 18C1-007
Corporate Income Tax
Sales Factor of Apportionment
Section (s.) 220.15, Florida Statutes (F.S.)
Rule 12C-1.0155, Florida Administrative Code (F.A.C.)
XXXXX
Dear XXXXX:
This is in response to your request dated XXXXX, for a Technical Assistance Advisement
("TAA") pursuant to section 213.22, F.S., and Rule Chapter 12-11, F.A.C., on how to correctly
source fees earned from services provided to related entities operating internationally.
FACTS SUPPLIED BY TAXPAYER
Taxpayer is a limited liability company organized under the laws of the United States1 and
treated as a C corporation for both federal and Florida corporate income tax purposes.

1

Taxpayer is incorporated in Florida.

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Taxpayer files on a calendar year basis. Taxpayer is a subsidiary of XXXXX (XXXXX or the XXXXX
Parent"), a XXXXX organized under the laws of XXXXX.
The XXXXX Parent operates through a number of other international affiliated entities (together
with Taxpayer and the XXXXX Parent, the “XXXXX Group”) to provide XXXXX services in XXXXX
and XXXXX. Taxpayer and the XXXXX Parent's subsidiary, XXXXX, are the sole wholly owned
members of the XXXXX Group that are located in and undertaking business activities in the
United States.
Taxpayer and XXXXX file separate income tax returns for federal and Florida tax purposes.
Neither the XXXXX Parent nor any of the other XXXXX affiliates file any federal or state income
tax returns.
The XXXXX Group operates in the XXXXX industry, primarily competing in the XXXXX segment,
which operate and maintain XXXXX facilities to provide direct XXXXX through XXXXX networks.
Specifically, the XXXXX Group provides XXXXX services, and XXXXX to more than XXXXX
customers in XXXXX and XXXXX. Currently, the XXXXX Group has XXXXX operations in XXXXX in
XXXXX and XXXXX under the XXXXX brand.
Taxpayer provides various XXXXX Services to the XXXXX Parent for the benefit of the XXXXX
Group. Taxpayer is primarily a regional support hub that assists the XXXXX Parent with XXXXX
and XXXXX the affiliated entities on their XXXXX of the XXXXX Group's XXXXX in the XXXXX
region. The XXXXX Parent compensates Taxpayer for its XXXXX of providing the XXXXX Services,
plus XXXXX, for the benefit of the XXXXX Group. A formal transfer pricing study2 has been
completed by a third party to assist in determining the arm's length rate at which the XXXXX
Parent is charged for the business transaction.
Taxpayer generates sales revenues through the performance of business support functions for
the benefit of the XXXXX Group. Taxpayer provides these business support functions to
affiliated entities located in foreign jurisdictions XXXXX. These services are often provided via
telephone or video conferencing, via electronic mail, or via the electronic transfer of computer
files through the internet.
Business support functions provided by Taxpayer include:
•

2

XXXXX Commercial Planning XXXXX
Includes XXXXX in the areas of XXXXX and coordination to the XXXXX Group.

XXXXX analysis and report, for the fiscal year ended December 31, 2016. XXXXX.

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•

Finance
Includes monitoring of business XXXXX activities of the XXXXX Group's business units by
XXXXX of new business units or XXXXX implemented by affiliates.

•

XXXXX Product Development
Includes XXXXX discussions about XXXXX projects executed by the affiliated entities
XXXXX.

•

Analytics
Includes providing XXXXX and XXXXX on business XXXXX and XXXXX to the XXXXX
affiliates' management groups.

•

Legal
Includes providing legal counseling and assistance XXXXX. Also includes assisting in
XXXXX regulation for all members in the XXXXX Group.

•

Marketing
Includes monitoring the XXXXX Group's implementation of XXXXX marketing XXXXX.
Also, Taxpayer aligns with the XXXXX affiliates to create XXXXX and XXXXX, which are
ultimately used by the XXXXX affiliates in their XXXXX activities XXXXX.

•

Human Resources
Includes supervising the XXXXX and XXXXX HR XXXXX for the XXXXX Group. Also includes
organizing XXXXX meetings and events and conducting trainings for XXXXX Group HR
managers, in addition to assisting the XXXXX Group in XXXXX management personnel for
the benefit of the XXXXX affiliate companies.

•

Customer Operations
Includes evaluating the XXXXX affiliates' XXXXX metrics against XXXXX standards from a
XXXXX perspective. Reports produced by Taxpayer assist the XXXXX Group in collection
of relevant information for the affiliates' development of XXXXX.

•

Sales, Distribution, and Tools
Includes XXXXX and XXXXX execution of the XXXXX Group XXXXX and XXXXX. Affiliates
independently evaluate the XXXXX and make the final decision on whether to adopt
Taxpayer's recommendations to their XXXXX. Taxpayer also provides XXXXX on XXXXX
and provides XXXXX to the XXXXX teams. XXXXX.

In all previous tax periods, Taxpayer has apportioned income to Florida pursuant to s. 220.15,
F.S. Taxpayer maintains XXXXX of its property within Florida and has traditionally reported a
property factor of XXXXX. The XXXXX of Taxpayer's payroll, with XXXXX of XXXXX employees

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working XXXXX from other states, is located in Florida. Taxpayer reported a payroll factor of
XXXXX on its Florida return for tax year 2016. Taxpayer has also reported a sales factor of
XXXXX, despite the fact that Taxpayer is "doing business within and without" Florida through
the provision of services to related entities located in XXXXX jurisdictions XXXXX. As a result of
this methodology, Taxpayer has traditionally reported a Florida apportionment fraction of
approximately XXXXX.3
XXXXX was formed and began filing Florida returns in XXXXX, but started doing business in
XXXXX. XXXXX provides services to the XXXXX Parent with a similar cost XXXXX for the usage of
XXXXX owned by XXXXX. XXXXX files XXXXX apportionment to Florida.
ISSUE PRESENTED
Taxpayer seeks advisement as to the Department's position regarding the sourcing of sales
revenues generated from the provision of services to related entities operating XXXXX.
LAW
Section 220.02(1), F.S., states in part:
It is the intent of the Legislature in enacting this code to impose a tax upon all
corporations, organizations, associations, and other artificial entities which derive
from this state or from any other jurisdiction permanent and inherent attributes
not inherent in or available to natural persons, such as perpetual life, transferable
ownership represented by shares or certificates, and limited liability for all
owners.… It is the intent of the Legislature to subject such corporations and other
entities to taxation hereunder for the privilege of conducting business, deriving
income, or existing within this state…. However, a corporation or other taxable
entity which is or which becomes partners with one or more natural persons shall
not, merely by reason of being a partner, exclude from its net income subject to
tax its respective share of partnership net income. This statement of intent shall
be given preeminent consideration in any construction or interpretation of this
code in order to avoid any conflict between this code and the mandate in s. 5, Art.
VII of the State Constitution that no income tax be levied upon natural persons
who are residents and citizens of this state.

Taxpayer's reported Florida apportionment fractions for tax years 2013-2015 were XXXXX and XXXXX
respectively.
3

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Section 220.15, F.S., provides in part:
(1) Except as provided in ss. 220.151, 220.152, and 220.153, adjusted federal
income as defined in s. 220.13 shall be apportioned to this state by taxpayers
doing business within and without this state by multiplying it by an apportionment
fraction composed of a sales factor representing 50 percent of the fraction, a
property factor representing 25 percent of the fraction, and a payroll factor
representing 25 percent of the fraction….

(2) The property factor is a fraction the numerator of which is the average value
of the taxpayer's real and tangible personal property owned or rented and used
in this state during the taxable year or period and the denominator of which is the
average value of such property owned or rented and used everywhere.

(4) The payroll factor is a fraction the numerator of which is the total amount paid
in this state during the taxable year or period by the taxpayer for compensation
and the denominator of which is the total compensation paid everywhere during
the taxable year or period.

(5) The sales factor is a fraction the numerator of which is the total sales of the
taxpayer in this state during the taxable year or period and the denominator of
which is the total sales of the taxpayer everywhere during the taxable year or
period.
(a) As used in this subsection, the term "sales" means all gross receipts of the
taxpayer except interest, dividends, rents, royalties, and gross receipts from the
sale, exchange, maturity, redemption, or other disposition of securities….

(7) The term "everywhere," as used in the computation of apportionment factor
denominators under this section, means "in all states of the United States, the
District of Columbia, the Commonwealth of Puerto Rico, any territory or
possession of the United States, and any foreign country, or any political
subdivision of the foregoing."

Rule 12C-1.015, F.A.C., provides in part:
Apportionment of Adjusted Federal Income.
(1) For taxable years beginning on or after January 1, 1991, corporations will
apportion their adjusted federal income in accordance with Section 220.15, F.S.,

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only if they are doing business within and without Florida. A taxpayer will be
considered doing business within and without this state if it has income from
business activity which is taxable both within and without Florida.
(a) In determining whether or not a taxpayer is doing business within and without
Florida, a taxpayer will be considered doing business without this state if the
corporation is taxable in another state, provided:

1. That state subjects the business to a net income tax, a franchise tax measured
   by net income, a franchise tax for the privilege of doing business, or a corporate
   stock tax, or,
2. That state has jurisdiction to subject the taxpayer to a net income tax regardless
   of whether, in fact, the state does or does not.
   (b)1. States have the jurisdiction to impose an income tax on any corporation that
   incorporates within their state. This is true regardless of whether the corporation
   exists or conducts business within their state. Therefore, corporations that have
   incorporated outside Florida may apportion income in accordance with Section
   220.15, F.S.
3. In general, whether a state has jurisdiction to subject a Florida corporation to a
   net income tax is dependent on whether the activities within the state fall within
   or without the limitations prescribed under the due process or commerce clauses.
4. The jurisdiction of a state to impose a net income tax is further limited by P.L.
   86-272 (15 U.S.C. ss. 381-384), which is incorporated by reference in Rule 12C1.0511, F.A.C., P.L. 86-272 precludes a state from taxing income from interstate
   commerce if a corporation's only business activity in the state is the solicitation of
   orders for sales of tangible personal property and the orders are approved and
   filled from outside the state.
5. The taxation by another state may also be limited by a de minimis exception. If
   the activity within a state is de minimis, or the activity that goes beyond the mere
   solicitation of orders for sales of tangible personal property is de minimis, a state
   is precluded from imposing an income tax. Whether a particular activity is a de
   minimis deviation from a prescribed standard must be determined with reference
   to the specific activity and all the facts of a specific case.
6. If no other state may tax a Florida corporation because of jurisdictional
   limitations due to the due process or commerce clauses, Public Law 86-272, or de
   minimis exceptions, the corporation will not be considered to be doing business
   within and without Florida.
7. If another state specifically rules that a Florida corporation is subject to a net
   income tax, a franchise tax measured by net income, a franchise tax for the
   privilege of doing business, or a corporate stock tax within that state, such ruling
   will be prima facie evidence that the state does have jurisdiction to tax.

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7. The fact that a corporation has voluntarily filed a return and paid tax in another
   state will not be conclusive proof that the state had jurisdiction to impose a
   corporate income tax.
8. For purposes of determining whether a corporation is doing business within and
   without the state when engaged in foreign commerce, the state will determine
   taxability in a foreign country as though the jurisdictional standards applicable to
   a state of the United States applied to that country. Therefore, if a foreign country
   actually imposes a tax measured by income on a corporation, the criteria of doing
   business within and without the state will be met. The corporation will also meet
   the criteria if when applying the standards of due process, the commerce clause,
   and P.L. 86-272, which is incorporated by reference in Rule 12C-1.0511, F.A.C., the
   foreign country would have jurisdiction to tax if it were a state of the United
   States.
   (c) Once it is determined that a corporation is subject to tax within another state
   or country, the corporation may apportion income using the property, payroll, and
   sales factors as prescribed in Section 220.15, F.S. The denominators of the
   apportionment factors will include the property, payroll, and sales everywhere.
   The denominators of the factors are not limited to only including the property,
   payroll, and sales in states which actually tax or have the jurisdiction to tax.
   (d) There is no throwback rule in Florida. For a corporation that is doing business
   within and without Florida, the sales are not considered to be Florida sales solely
   because the corporation is not subject to tax within another state.

Rule 12C-1.0155, F.A.C., provides in part:
(1) For the purposes of the sales factor, the term "sales" means all gross receipts
received by the taxpayer from transactions and activities in the regular course of
its trade or business.

(h) Sales of services. In the case of a taxpayer engaged in providing services, such
as the operation of an advertising agency, the performance of equipment service
contracts, or research and development contracts, "sales" includes the gross
receipts from the performance of such services including fees, commissions, and
similar items.

(2) Florida sales. The numerator of the sales factor includes gross receipts
attributed to Florida which were derived by the taxpayer from transactions and

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activities in the regular course of its trade or business. All interest income, service
charges, carrying charges, or time-price differential charges incident to such gross
receipts shall be included, regardless of the place where the account records are
maintained or the location of the contract or other evidence of indebtedness.

(l) Other Sales in Florida. Gross receipts from other sales shall be attributed to
Florida if the income producing activity which gave rise to the receipts is
performed wholly within Florida. Also, gross receipts shall be attributed to Florida
if the income producing activity is performed within and without Florida but the
greater proportion of the income producing activity is performed in Florida, based
on costs of performance. The term "income producing activity" applies to each
separate item of income and means the transactions and activity directly engaged
in by the taxpayer for the ultimate purpose of obtaining gains or profits. Where
independent contractors are used to complete a contract, the term "income
producing activity" will include amounts paid to the independent contractors.
(Emphasis supplied)
ANALYSIS
Reliance on Technical Assistance Advisements
Taxpayer cites several TAAs issued by the Department in support of its assertion that its sales
receipts for the professional services provided to international affiliate entities should be
sourced pursuant to Rule 12C-1.0155(2)(l), F.A.C., because Taxpayer's "income producing
activity" is the delivery of the business XXXXX services to the XXXXX affiliate entities, which
occur in XXXXX jurisdictions. TAAs are binding on the Department only under the facts and
circumstances described in the request for a specific taxpayer. Section 213.22(1), F.S., states,
"Technical assistance advisements shall have no precedential value except to the taxpayer who
requests the advisement…." Therefore, other TAAs have not been taken into consideration
when reviewing Taxpayer's request.
Is Apportionment of Adjusted Federal Income Permitted?
Taxpayers conducting business within and without Florida apportion their adjusted federal
income by multiplying it by an apportionment fraction composed of a sales factor representing
50 percent of the fraction, a property factor representing 25 percent of the fraction, and a
payroll factor representing 25 percent of the fraction. See s. 220.15, F.S.

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Because Taxpayer is incorporated in Florida, and XXXXX of its property is located in Florida, the
question of whether Taxpayer is permitted to apportion its income at all must be addressed.
Pursuant to Rule 12C-1.015, F.A.C., a corporation is permitted to apportion its income only if it
is found to be doing business within and without Florida. A taxpayer is considered to be doing
business within and without Florida if the corporation is taxable in another state, provided that
that state subjects the taxpayer to an income tax or has jurisdiction to subject the taxpayer to
an income tax, regardless of whether the state does or does not.
For tax year 2015, Taxpayer has established that it was permitted to apportion its income for
Florida tax purposes because it was subject to income tax and required to file a corporate
income tax return in two other states for that tax year, California and Virginia.
Taxpayer was required to file California Form 100W (California Corporation Franchise or Income
Tax Return – Water's-Edge Filers) because "[t]he amount paid in California by the taxpayer for
compensation, as defined in R&TC Section 25120(c), exceeds the lesser of $53,644 or 25% of
the total compensation paid by the taxpayer."4 5 See also Revenue and Taxation Code (R&TC)
Section 23101 for the definition of "doing business" in California.
Taxpayer's 2015 Virginia Corporation Income Tax Return reported income of $XXXXX subject to
Virginia tax and an apportionment factor percentage of XXXXX%, based solely on the payroll
factor.6 Taxpayer paid $XXXXX income tax to Virginia. It should be noted that Taxpayer checked
the "Initial Filer" box with this return.
Taxpayer provided a formal job description for the "XXXXX Manager XXXXX" position for its outof-state employees, which demonstrates that the activities of an employee in that position are
not protected by Public Law 86-272 (i.e., the employee performs duties other than the
solicitation of orders for the sale of tangible personal property).
In addition to returns filed in California and Virginia, Taxpayer provided copies of the corporate
income tax returns it filed in states other than Florida for taxable year 2015, although it is
unclear whether Taxpayer was required to file such returns. Except for its corporate income tax
return filed in Virginia, Taxpayer either paid $0 tax due or the state minimum tax. 7
4

California Forms & Instructions 100W 2015 Corporation Tax Booklet Water's-Edge Filers
Taxpayer provided copies of California Forms DE 9 (Quarterly Contribution Return and Report of Wages) and DE
9C (Quarterly Contribution Return and Report of Wages(Continuation)) for its California employee. Compensation
paid in California by Taxpayer for tax year 2015 exceeded $53,644.
6
Taxpayer provided copies of Virginia Forms VEC-FC-21 (Employer's Quarterly Payroll Report) and VEC-FC-20
(Employer's Quarterly Tax Report) for its Virginia employee.
5

7

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Sales Factor of Apportionment
Section 220.02(1), F.S., provides that it is the intent of the Florida Legislature to impose a
corporate income tax on every taxpayer in each taxable year for the privilege of conducting
business, earning income, or existing in Florida. The apportionment fraction provides a
measure of a taxpayer's business activity in the states in which it does business and serves as a
means of attributing income to the states from which the income was derived.
Section 220.15(5), F.S., defines the sales factor as "a fraction, the numerator of which is the
total sales of the taxpayer in this state during the taxable year or period and the denominator
of which is the total sales of the taxpayer everywhere during the taxable year or period."
Rule 12C-1.0155, F.A.C., describes how the receipts from several types of sales activities are
computed, and then provides information on the computation of the Florida portion of those
receipts. Rule 12C-1.0155(2), F.A.C., provides that "the numerator of the sales factor includes
gross receipts attributed to Florida which were derived by the taxpayer from transactions and
activities in the regular course of its trade or business."
In this case, Taxpayer's activities do not constitute the sale of tangible personal property.
Therefore, the discussion below will focus on the sourcing of sales other than those of tangible
personal property, namely the sale of services.
Rule 12C-1.0155(2)(l), F.A.C., focuses on each separate item of income and the activities which
produce that income. To paraphrase that rule, sales are attributed to Florida if the income
producing activity which gave rise to the receipt is within Florida. The income producing
activity is not analyzed holistically as one major activity, but each individual transaction is
considered a separate transaction and consequently a separate income producing activity.
The term "income producing activity" is defined in Rule 12C-1.0155(2)(l), F.A.C., as "the
transactions and activity directly engaged in by the taxpayer for the ultimate purpose of
obtaining gains or profits." The word "and" signifies that both transactions and activities must
exist simultaneously in order for any activity to be considered the income producing activity.
The word "transaction" is used several times in the Florida Statutes and Florida Administrative
Code, but it is not defined.
Absent a statutory definition, words should be given their plain and ordinary meaning, and one
looks to the dictionary for the plain and ordinary meaning of words. Sudath Van Lines, Inc. v.
Department of Environmental Protection, 668 So.2d 209, 212 (Fla. 1st DCA 1996).

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Black's Law Dictionary8 defines "transaction" as:
Act of transacting or conducting any business; between two or more persons;
negotiation; that which is done; an affair. An act, agreement, or several acts or
agreements between or among parties whereby a cause of action or alteration of
legal rights occur. It may involve selling, leasing, borrowing, mortgaging or lending.
Under Rule 12C-1.0155(2)(l), F.A.C., when the activity producing the sales revenue occurs
entirely or predominately in Florida, the receipts from the Florida activity are deemed to be a
Florida sale.
Here, the subject transaction is XXXXX provision of “XXXXX Services" to XXXXX for the benefit of
the XXXXX Group. XXXXX compensates Taxpayer for its total cost of providing the XXXXX
Services, plus XXXXX.
Pursuant to the XXXXX Services Agreement provided by Taxpayer, Taxpayer invoices XXXXX on a
regular basis, and XXXXX settles the invoices within sixty (60) days by paying the XXXXX Services
Fee to the credit of a bank account designated by Taxpayer.
The income producing activity for the XXXXX Services performed for Taxpayer's customer is the
purchase of those services by its customer, who is physically located in XXXXX. Therefore, none
of Taxpayer's XXXXX Services Fees XXXXX are sourced to Florida.
CONCLUSION
In tax years when Taxpayer is permitted to apportion its Florida taxable income because it is
considered to be doing business within and without Florida, the apportionment guidelines
offered in s. 220.15, F.S., and Rules 12C-1.0153, 12C-1.0154, and 12C-1.0155, F.A.C., should be
followed.
Pursuant to Rule 12C-1.0155(2)(l), F.A.C., when the activity producing the sales revenue occurs
entirely in Florida, the receipts from the Florida activity are deemed to be Florida sales. The
income producing activity occurs entirely in Florida when Taxpayer's customer is physically
located in Florida.
This response constitutes a Technical Assistance Advisement under section 213.22, F.S., which
is binding on the Department only under the facts and circumstances described in the request
8

Abridged Sixth Edition (1991)

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for this advice as specified in section 213.22, F.S. Our response is based on those facts and
specific situation summarized above. You are advised that subsequent statutory or
administrative rule changes or judicial interpretations of the statutes or rules upon this advice is
based may subject future transactions to a different treatment than expressed in this response.
You are further advised that this response, your request and related backup documents are
public records under Chapter 119, F.S., and are subject to disclosure to the public under the
conditions of section 213.22, F.S. Confidential information must be deleted before public
disclosure. In an effort to protect confidentiality, we request you provide the undersigned with
an edited copy of your request for Technical Assistance Advisement, the backup material and
this response, deleting names, addresses and any other details which might lead to
identification of the taxpayer. Your response should be received by the Department within 15
days of the date of this letter.
Sincerely,

Jennifer M. Ensley
Jennifer M. Ensley
Senior Tax Specialist
Technical Assistance and Dispute Resolution
(850) 717-7659
AMS No. 18017
Cc: XXXXX
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