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SC SC Information Letter #23-18 Income Tax 2023-12-06

What are South Carolina's 2024 county tier rankings for the job tax credit, and which counties qualify for the tax moratorium and reduced fee-in-lieu investment?

Short answer: SC Information Letter #23-18 sets the 2024 county rankings that drive several South Carolina incentives. For the job tax credit, all 46 counties are ranked into four tiers (Tier IV counties are the most distressed and get the largest per-job credit) using equal weight on unemployment rate and per capita income under Code Section 12-6-3360(B), for new full-time jobs created in tax years beginning in 2024. The 2024 Tier IV (most distressed) counties are Abbeville, Allendale, Bamberg, Barnwell, Cherokee, Chesterfield, Dillon, Lee, Marion, Marlboro, Orangeburg, Union, and Williamsburg; Tier I (least distressed) includes Aiken, Beaufort, Charleston, Dorchester, Greenville, Lancaster, Lexington, Newberry, Oconee, and York. For the corporate income/insurance premium tax moratorium under Section 12-6-3367, the 2024 qualifying counties are Chesterfield, Dillon, and Marlboro. For the fee in lieu of property taxes, Marlboro County qualifies for the reduced $1 million minimum investment (Little Fee, Simplified Fee, and Big Fee) for 2024.

Apply this to your situation

This page answers the general question as of 2023. Ezel answers yours, under current South Carolina tax law, with citations.

Disclaimer: This is an official South Carolina Department of Revenue Information Letter. Per the Department, an Information Letter announces general information useful in complying with the laws administered by the Department and has NO precedential value. County tiers, moratorium counties, and reduced-investment counties are re-ranked ANNUALLY — these designations apply to 2024 and change each year, so use the ranking for your credit year. This summary is informational only and is not legal or tax advice. Consult a licensed South Carolina tax professional about your situation.
About this page: The plain-English summary, reader guidance, and Q&A below were written by Ezel based on the official state tax ruling. The original ruling (linked on this page as a PDF) is the authoritative source for any reliance.
View original ruling (PDF)

Plain-English summary

This Information Letter publishes South Carolina's 2024 county rankings that set the size of the job tax credit, plus which counties qualify for the corporate tax moratorium and the reduced fee-in-lieu investment threshold. These designations change every year.

The job tax credit, the corporate tax moratorium, and the reduced minimum fee-in-lieu investment all depend, in part, on per capita income and unemployment data from the South Carolina Department of Employment and Workforce and the U.S. Department of Commerce.

Job tax credit — 2024 county tiers

Under Code Section 12-6-3360(B), all 46 counties are ranked annually into four tiers, with equal weight on 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 below apply to new full-time jobs created in tax years beginning in 2024 (credit first earned on or after January 1, 2024) and to increases in new full-time jobs in 2024:

  • Tier IV (most distressed): Abbeville, Allendale, Bamberg, Barnwell, Cherokee, Chesterfield, Dillon, Lee, Marion, Marlboro, Orangeburg, Union, Williamsburg
  • Tier III: Calhoun, Chester, Clarendon, Colleton, Darlington, Fairfield, Greenwood, Hampton, Horry, Laurens, McCormick, Sumter
  • Tier II: Anderson, Berkeley, Edgefield, Florence, Georgetown, Jasper, Kershaw, Pickens, Richland, Saluda, Spartanburg
  • Tier I (least distressed): Aiken, Beaufort, Charleston, Dorchester, Greenville, Lancaster, Lexington, Newberry, Oconee, York

Corporate tax moratorium — 2024 counties

Under Code Section 12-6-3367, a qualifying taxpayer can receive a 10-year (15 years in certain cases) moratorium on corporate income or insurance premium taxes in a county with very high unemployment (at least twice the state average for the last two completed calendar years) or one of the three lowest per capita incomes. For 2024 the moratorium counties are Chesterfield, Dillon, and Marlboro.

Fee in lieu of property taxes — reduced investment for 2024

The minimum investment to qualify for a fee in lieu of property taxes is normally $2.5 million (Little Fee and Simplified Fee) or $45 million (Big Fee), but it drops to $1 million for a company investing in a county with unemployment at least twice the state average over the last 24 months. For 2024, Marlboro County qualifies for the reduced $1 million minimum under the Little Fee, Simplified Fee, and Big Fee.

What this means for you

Businesses planning job creation or a capital investment

The county where you create jobs or invest drives the incentive. A Tier IV county yields a larger per-job credit than a Tier I county, and the same handful of high-distress counties (here Chesterfield, Dillon, Marlboro) also unlock the moratorium and the reduced fee-in-lieu investment. Match your project's county to the 2024 designation.

Use the right year

These tiers and lists are re-ranked every year. Use the ranking that applies to the year the job is created or the credit is first earned, not a prior year's letter. For computation details, see SC Revenue Ruling #19-11.

Common questions

Q: Which counties give the biggest South Carolina job tax credit in 2024?
A: Tier IV (most distressed) counties: Abbeville, Allendale, Bamberg, Barnwell, Cherokee, Chesterfield, Dillon, Lee, Marion, Marlboro, Orangeburg, Union, and Williamsburg.

Q: Which counties qualify for the corporate tax moratorium for 2024?
A: Chesterfield, Dillon, and Marlboro, under Code Section 12-6-3367.

Q: Do these rankings change?
A: Yes, every year. The Department re-ranks all 46 counties annually based on updated unemployment and per capita income data, so use the designation for your credit year.

Source

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 #23-18
SUBJECT:

Job Tax Credit - County Rankings for 2024
Fee in Lieu of Property Taxes – Reduced Investment Counties
Tax Moratorium – Qualifying Counties

DATE:

December 6, 2023

REFERENCE:

S. C. Code Ann. Section 12-6-3360 (2014; Supp. 2023)
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. 2023)
S. C. Code Ann. Section 4-29-67 (Supp. 2023)

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 corporate 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 2024, where the job tax credit was first earned on or after January 1, 2024,
and (2) increases in new full-time jobs in 2024 are listed below. 1
TIER IV
Abbeville
Allendale
Bamberg
Barnwell
Cherokee
Chesterfield
Dillon
Lee
Marion
Marlboro
Orangeburg
Union
Williamsburg

TIER III

TIER II

Calhoun
Chester
Clarendon
Colleton
Darlington
Fairfield
Greenwood
Hampton
Horry
Laurens
McCormick
Sumter

Anderson
Berkeley
Edgefield
Florence
Georgetown
Jasper
Kershaw
Pickens
Richland
Saluda
Spartanburg

TIER I
Aiken
Beaufort
Charleston
Dorchester
Greenville
Lancaster
Lexington
Newberry
Oconee
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 2024, the following counties have been designated moratorium counties under South
Carolina Code Section 12-6-3367.
Chesterfield
Dillon
Marlboro
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 2024, Marlboro 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

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