The Comptroller on January 20, 2023, proposed amendments to its margin tax apportionment rule. The revised rule removes the “receipts-producing, end-product act” test that was invalidated by the Texas Supreme Court in the Sirius XM litigation. In its place, language is added providing that a service is performed at the location or locations where the taxable entity’s personnel or property are doing the work that the customer hired the taxable entity to perform.
Source: KPMG
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