Market Sourcing For Business Income Tax Apportionment

Income tax - corporate - apportionment rules for taxpayer that has income from the sale of services or the sale of intangible property. For income tax years commencing on and after January 1, 2019, the act generally replaces the method for sourcing of sales for purposes of apportioning the income of a taxpayer that has income from the sale of services or from the sale, lease, license, or rental of intangible property in both Colorado and other states from the cost-of-performance test in the case of services and the commercial domicile test in the case of intangible property to a market-based sourcing system. Under this new system, receipts for the sale of services or from the sale, lease, license, or rental of intangible property are apportioned to Colorado based not on where the service is performed, but where the service is delivered.
(Note: This summary applies to this bill as enacted.)