Tractor Supply Co. v. SCDOR — Court Upholds Combined Unitary Reporting for South Carolina Corporate Tax
The South Carolina Court of Appeals affirmed the Administrative Law Court’s approval of combined unitary reporting (CUR) as the Department of Revenue’s alternative apportionment method for Tractor Supply Company’s 2014–2016 tax years, holding that artificially inflated intercompany transfer pricing that shifted income to a non-filing affiliate distorted the standard sales factor formula, and that CUR is an authorized and reasonable remedy under § 12-6-2320(A) and Media General.