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Tennessee Issues Nexus Guidance for Transportation Companies

Posted 5:00 AM by

Tennessee issued the Revenue Ruling #17-08, which details nexus for transportation companies. Below is a summary of this ruling and key points to be aware of as transportation activity nexus is contemplated for the 2017 tax year.

“Substantial nexus” can be created in Tennessee either by having a specific connection with the state that would be enough to impose tax or by exceeding any of the bright-line presence thresholds. For purposes of this ruling, Tennessee focused on the first part of the nexus standard.

The ruling details that transportation companies create substantial nexus in the state if any of the following occur:

a) The transportation company provides intrastate transportation services within Tennessee,
b) makes deliveries of goods into Tennessee that originate in another state, or
c) transports goods from Tennessee for delivery into another state.

The ruling dictates that traveling through Tennessee with trips that do not originate or terminate in Tennessee where the vehicles do not make any pickups or deliveries in Tennessee and the company conducts no other business activity in Tennessee does not constitute doing business in Tennessee.

It is important to understand that this is not a law change. Through this ruling, Tennessee is now on record outlining its formal policy on nexus-creating activities for transportation companies. 

If you have questions about state nexus or filing requirements in Tennessee or any other state, please contact a KSM advisor. 


About the Author
Amy Zimmer is a director in Katz, Sapper & Miller's State and Local Tax Group. Amy advocates for clients in the multistate tax arena, protecting their assets by resolving complex compliance issues and negotiating settlements with taxing jurisdictions. Connect with her on LinkedIn.


About the Author
Randy Hooper is a partner in Katz, Sapper & Miller’s Transportation Services Group. Randy helps carriers realize greater company value by advising them on corporate structure, strategic tax planning, and by providing general business guidance. Connect with him on LinkedIn.

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