What are South Carolina's 2023 county tier rankings for the job tax credit, and which counties qualify for the tax moratorium and reduced fee-in-lieu investment?

Plain-English summary

This Information Letter publishes South Carolina's 2023 county rankings that determine three economic-development incentives: the job tax credit, the corporate tax moratorium, and the reduced minimum investment for the fee in lieu of property taxes. The rankings are recalculated each year from unemployment-rate and per capita income data.

Job tax credit — county tiers. All 46 counties are ranked into four tiers under Code Section 12-6-3360(B), giving equal weight to unemployment rate and per capita income. Tier IV counties are the most economically distressed and carry the largest per-job credit; Tier I the least. The rankings apply to new full-time jobs created in tax years beginning in 2023 (where the credit was first earned on or after January 1, 2023). The 2023 Tier IV counties are Allendale, Bamberg, Barnwell, Cherokee, Chester, Dillon, Lee, Marion, Marlboro, Orangeburg, Union, and Williamsburg. The 2023 Tier I counties are Aiken, Beaufort, Berkeley, Charleston, Greenville, Kershaw, Lexington, Newberry, Oconee, Richland, and York.

Corporate tax moratorium. Under Code Section 12-6-3367, qualifying taxpayers in certain highly distressed counties can get a 10-year (15 years in certain cases) moratorium on corporate income or insurance premium taxes. The 2023 moratorium counties are Chesterfield, Dillon, and Jasper.

Fee in lieu of property taxes (FILOT). The minimum required investment to qualify is normally $2.5 million for the "Little Fee" and "Simplified Fee" and $45 million for the "Big Fee," but it drops to $1 million in certain distressed counties. For 2023, no county qualifies for the reduced $1 million minimum investment.

What this means for you

If your business is creating jobs or making a capital investment in South Carolina, the county where you locate can materially change your tax benefit. A Tier IV county yields a larger per-job credit than a Tier I county; locating in a 2023 moratorium county (Chesterfield, Dillon, or Jasper) can suspend corporate income or insurance premium tax for a decade or more; and the FILOT minimum-investment threshold depends on the county. Because these lists are reset annually, match the year of your job creation or investment to the correct Information Letter — this one governs 2023.

Common questions

Q: Which 2023 counties give the largest job tax credit?
A: The Tier IV (most distressed) counties: Allendale, Bamberg, Barnwell, Cherokee, Chester, Dillon, Lee, Marion, Marlboro, Orangeburg, Union, and Williamsburg.

Q: Which counties qualify for the corporate tax moratorium in 2023?
A: Chesterfield, Dillon, and Jasper, under Code Section 12-6-3367.

Q: Did any county qualify for the reduced $1 million fee-in-lieu investment in 2023?
A: No. For 2023, no county qualified for the reduced $1 million minimum; the standard minimums ($2.5 million / $45 million) applied.

Source

• Landing page: https://dor.sc.gov/advisory-opinion-search
• Original PDF: https://dor.sc.gov/sites/dor/files/policies/IL22-23.pdf

Original ruling text

STATE OF SOUTH CAROLINA

DEPARTMENT OF REVENUE
300A Outlet Pointe Blvd., Columbia, South Carolina 29210
P.O. Box 125, Columbia, South Carolina 29214-0575

SC INFORMATION LETTER #22-23
SUBJECT:

Job Tax Credit - County Rankings for 2023
Fee in Lieu of Property Taxes – Reduced Investment Counties
Tax Moratorium – Qualifying Counties

DATE:

December 14, 2022

REFERENCE:

S. C. Code Ann. Section 12-6-3360 (2014; Supp. 2020)
S. C. Code Ann. Section 12-6-3367 (2014)
S. C. Code Ann. Section 12-44-30 (2014)
S. C. Code Ann. Section 4-12-30 (Supp. 2020)
S. C. Code Ann. Section 4-29-67 (Supp. 2020)

AUTHORITY:

S.C. Code Ann. Section 12-4-320 (2014)
S.C. Code Ann. Section 1-23-10(4) (2005)
SC Revenue Procedure #09-3

SCOPE:

An Information Letter is a written statement issued to the public to announce
general information useful in complying with the laws administered by the
Department. An Information Letter has no precedential value.

INTRODUCTION
The job tax credit, the tax moratorium, and the reduction in the minimum required fee in lieu of
property tax investment are dependent, in part, on per capita income and unemployment rate data
received from the South Carolina Department of Employment and Workforce and the United
States Department of Commerce.
The purpose of this information letter is to provide the county rankings for purposes of the job
tax credit, counties qualifying for the corporate tax moratorium, and counties qualifying for the
reduced fee in lieu of property tax.
JOB TAX CREDIT – County Rankings
South Carolina’s 46 counties are ranked and designated annually for job tax credit purposes with
equal weight given to unemployment rate and per capita income as provided in South Carolina
Code Section 12-6-3360(B). The final ranking of counties for (1) new full-time jobs created in

1

tax years that begin in 2023, where the job tax credit was first earned on or after January 1, 2023,
and (2) increases in new full-time jobs in 2023 are listed below. 1
TIER IV
Allendale
Bamberg
Barnwell
Cherokee
Chester
Dillon
Lee
Marion
Marlboro
Orangeburg
Union
Williamsburg

TIER III

TIER II

Abbeville
Chesterfield
Clarendon
Colleton
Darlington
Fairfield
Greenwood
Horry
Jasper
Laurens
McCormick
Sumter

Anderson
Calhoun
Dorchester
Edgefield
Florence
Georgetown
Hampton
Lancaster
Pickens
Saluda
Spartanburg

TIER I
Aiken
Beaufort
Berkeley
Charleston
Greenville
Kershaw
Lexington
Newberry
Oconee
Richland
York

TAX MORATORIUM – Qualifying Counties
South Carolina Code Section 12-6-3367, in part, grants a 10-year moratorium (15 years in certain
cases) on corporate income taxes or insurance premium taxes for qualifying taxpayers in a
county with an average annual unemployment rate of at least twice the state average during each
of the last two completed calendar years, based on the most recent unemployment rates available,
or in a county with one of the three lowest per capita incomes based on the average of the three
most recent years of available average per capita income data. The moratorium begins the first
full taxable year after the taxpayer qualifies in a county designated as a moratorium county.
For 2023, the following counties have been designated moratorium counties under South
Carolina Code Section 12-6-3367.
Chesterfield
Dillon
Jasper
FEE IN LIEU OF PROPERTY TAXES - Reduced Investment Counties
The minimum required investment necessary to qualify for the fee in lieu of property taxes is
$2.5 million for the “Little Fee” and “Simplified Fee,” and $45 million for the “Big Fee.” See
South Carolina Code Sections 4-12-30(B)(3), 12-44-30(14), and 4-29-67, respectively. This
investment amount, however, is reduced to $1 million for a company investing in a county with
an average annual unemployment rate of at least twice the state average during each of the last
24 months, based on data available on November 1.
For 2023, no county qualifies for the $1 million minimum investment under the “Little Fee,”
“Simplified Fee,” and “Big Fee.”
1

For further information, see SC Revenue Ruling #19-11, Question 3 and the examples provided.

2