Tennessee Code Annotated

Tenn. Code Ann. § 67-4-2010 (2026)

Taxation of persons doing business outside state

✓ current as of May 2026

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(a) Any taxpayer having business activities that are taxable both inside and outside this state shall allocate or apportion its net earnings or losses as provided in this part. A taxpayer is considered taxable in another state only if the taxpayer is conducting activities in that state that, if conducted in Tennessee, would constitute doing business in Tennessee and would subject the taxpayer to either Tennessee's franchise tax or excise tax.

(b) Nonbusiness receipts shall not be included in the numerator or denominator of any apportionment formula.

Acts 1999, ch. 406, § 3; 2006, ch. 1019, § 22.

Notes of Decisions

Cited in 5 cases, 2009–2018 · leading case: Bellsouth Advert. & Publ'g Corp. v. Chumley, 308 S.W.3d 350 (Tenn. Ct. App. 2009).

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Bellsouth Advert. & Publ'g Corp. v. Chumley, 308 S.W.3d 350 (Tenn. Ct. App. 2009). · cites it 3× “Tenn.Code Ann. § 67-4-2010 was amended in 2006, however as the amendment applies to tax years beginning on or after January 1, 2006 it has no implication here.”

Blue Bell Creameries, LP v. Roberts, 333 S.W.3d 59 (Tenn. 2011). · cites it 2× “” Tenn.Code Ann. § 67-4-2010 (Supp.2000). Tennessee Code Annotated section 67-4-2011 (Supp.”

Popularcategories.com, Inc. v. David Gerregano, Comm'r Of Revenue, State of Tennessee (Tenn. Ct. App. 2018). · cites it 4× “Tenn. Code Ann. § 67-4-2010 . (a) Any taxpayer having business activities that are taxable both inside and outside the state of Tennessee shall allocate or apportion its net worth as provided in this part.”

H.J. Heinz Co., L.P. v. Loren L. Chumley, Commissioiner of Revenue, State of Tennessee (Tenn. Ct. App. 2011). · cites it 2× “768 (1992); Tenn. Code Ann. §§ 67-4-2010 to 2013(2006 & Supp.”

Vodafone Americas Holdings Inc. & Subsidiaries v. Richard H. Roberts, Comm'r of Revenue, State of Tennessee (Tenn. Ct. App. 2014). · cites it 2× “Tennessee’s franchise and excise tax statutory scheme requires companies to pay taxes on their net earnings or losses as provided in Tenn. Code Ann. § 67-4-2010 et seq., and on their net worth as provided in Tenn.”

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