South Carolina Issues Draft Revenue Ruling And Procedure On Alternative Apportionment Methods Including Unitary Reporting

The South Carolina Department of Revenue has issued a draft revenue ruling and revenue procedure relating to alternative apportionment that may have significant application to taxpayers. The draft ruling outlines the Department's position with respect to alternative apportionment methods which may be requested by the taxpayer or required by the Department, and specifically discusses the applicability of unitary reporting as a method of alternative apportionment.¹ The draft procedure details the steps necessary for a taxpayer seeking approval for an alternative apportionment method to submit an application with the Department.²

Draft Revenue Ruling #15-x

South Carolina has historically utilized separate entity reporting, requiring a taxpayer to compute and apportion its income to the state separately for each legal entity within an organizational structure.³ When either the taxpayer or the Department believes the statutory reporting method does not fairly represent