Tennessee Code Annotated

Tenn. Code Ann. § 67-4-2110 (2026)

Apportionment for 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 the state of Tennessee shall allocate or apportion its net worth 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, § 4; 2006, ch. 1019, § 23.

Notes of Decisions

Cited in 3 cases, 2014–2018 · leading case: Vodafone Americas Holdings, Inc. & Subsidiaries v. Richard H. Roberts, Comm'r of Revenue, State of Tennessee, 486 S.W.3d 496 (Tenn. 2016).

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Vodafone Americas Holdings, Inc. & Subsidiaries v. Richard H. Roberts, Comm'r of Revenue, State of Tennessee, 486 S.W.3d 496 (Tenn. 2016). · cites it 2× “…U.S.C. § 267 (f)(1)‖ after ―as defined in § 267(f)(1) of the Internal Revenue Code‖ in subsection (e) and cites to ―§§ 67-4-2110 and 67-4-2111,‖ whereas section 67-4-2014 cites to ―§§ 67-4-2011 and 67-4- 2012.‖ See Tenn. Code Ann. §§ 67-4-2014 , -2112. 30 difference‖ from the…”

Popularcategories.com, Inc. v. David Gerregano, Comm'r Of Revenue, State of Tennessee (Tenn. Ct. App. 2018). · cites it 4× “Tenn. Code Ann. § 67-4-2110 . As both parties acknowledge, doing business in this state means “any activity purposefully engaged in within Tennessee, by a person with the object of gain, benefit, or advantage, consistent with the intent of the general assembly to subject such…”

Vodafone Americas Holdings Inc. & Subsidiaries v. Richard H. Roberts, Comm'r of Revenue, State of Tennessee (Tenn. Ct. App. 2014). · cites it 3× “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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