3PA-20S/PA-65 H www.revenue.pa.gov
SALES FACTOR (SALES)
The sales factor is a fraction. The numerator is total gross
receipts derived from sales in Pennsylvania during the
taxable year. The denominator is total gross receipts derived
from all sales during the taxable year. The sales factor
includes income such as interest, dividends, or from property
dispositions, but only to the extent described in these
instructions.
CALCULATING SALES FACTOR
For purposes of calculating the sales factor, only sales
of stock-in-trade or inventory held primarily for sale to
customers in the ordinary course of the business, sales of
services to customers, and sales of certain assets shall be
taken into account. A sale of stock-in-trade or inventory is in
Pennsylvania if:
● The seller delivers or ships the property from outside
Pennsylvania into Pennsylvania to any purchaser other
than the federal government;
● The seller delivers or ships the property from Pennsyl-
vania and the purchaser is the federal government;
● The seller delivers or ships the property from Pennsyl-
vania to another state or country, and the other state or
country has no jurisdiction to tax the net income of the
business derived from such sales; or
● The seller delivers or ships the property from a point
within Pennsylvania to a purchaser in Pennsylvania.
A sale of services is in Pennsylvania if the seller performs
the services wholly within Pennsylvania.
A sale of services is in Pennsylvania if the seller performs a
greater portion of the services in Pennsylvania than outside
Pennsylvania, based on cost or performance. A sale of a tan-
gible asset in Pennsylvania is a sale of property within Penn-
sylvania. A sale of certain intangible assets employed in a
going concern in Pennsylvania is a sale of property within
Pennsylvania.
ALLOCATING GAIN (LOSS) FROM THE DISPOSITION
OF TANGIBLE PROPERTY
Generally, the revenue, cost, expense, and liability that a PA
S corporation or partnership derives from or incurs in the
sale, exchange or disposition of real property or tangible per-
sonal property is entirely derived from or incurred in the state
or country in which the property is physically located.
Special rules, however, apply with respect to the following:
● Stock-in-trade or other property of a kind the entity in-
cludes in its inventory at the close of the taxable year;
● Property the entity holds primarily for sale to customers
in the ordinary course of its business operations; and
● Tangible and intangible assets the entity employs in a
line of business.
Gross proceeds from the disposition of tangible property is
included in the sales factor with respect to such assets if:
● The entity reinvests proceeds from the sale of the assets
in the same line of business (as defined by the North
American Industry Classification System (NAICS) code)
within the same entity; and
● The entity must use the proceeds to acquire like-kind
property used in the same business, profession, or farm.
GAIN (LOSS) FROM THE DISPOSITION OF
INTANGIBLE PERSONAL PROPERTY, OTHER
THAN GOODWILL
Generally, the revenue, cost, expense and liability that the
PA S corporation or partnership derives from or incurs in the
sale, exchange or disposition of intangible personal property
other than goodwill from the disposition of a going concern,
is derived from or incurred in the state or country in which
the entity has physical presence. Refer to Personal Income
Tax Bulletin 2005-02, Gain or Loss Derived from the Dispo-
sition of a Going Concern.
Gross proceeds from the disposition of intangible personal
property other than goodwill is included in the sales factor
with respect to such assets if:
● The entity reinvests proceeds from the sale of the assets
in the same line of business (as defined by the North
American Industry Classification System (NAICS) code)
within the same entity;
● The entity must use the proceeds to acquire like-kind
property used in the same business, profession, or farm.
INTEREST INCOME
Generally, the PA S corporation or partnership allocates any
item of interest, cost, expense or liability incurred in the
production of interest.
The PA S corporation or partnership classifies interest as net
profits and therefore apportions the interest along with other
net profits in the following instances:
● Interest the PA S corporation or partnership derives
from, and costs, expenses or liabilities the PA S corpo-
ration or partnership incurs in connection with, purchase
money mortgages on real estate or land contracts;
● Interest the PA S corporation or partnership derives
from, and costs, expenses or liabilities the PA S corpo-
ration or partnership incurs in connection with, assets it
employs as working capital (generally current assets) in
its business and from accounts and notes receivable
from sales or products or services it sells in the ordinary
course of business; and
● Interest incidental to the production or collection of rental
or royalty income.
The PA Personal Income Tax Guide sets forth in detail the
rules for classifying interest income. Interest that is not net
profits may be classified as interest income, net rental
income or net gains.
DIVIDEND INCOME
Generally, the PA S corporation or partnership allocates any
item of dividend, cost, expense or liability incurred in the pro-
duction of dividends. The special rules for allocating interest
income described previously also apply to dividend income.
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