We're tracking 2 live transfer pricing roles in Minnesota.
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Transfer pricing in Minnesota examines the pricing of intercompany transactions between related entities, focusing on ensuring these transactions are conducted at arm's length. This is crucial for accurately determining taxable income allocated to Minnesota for corporate franchise tax purposes.
Minnesota imposes a corporate franchise tax on C corporations, with a top rate of 9.8%, and requires combined reporting for unitary business groups. The state incorporates federal transfer pricing principles (e.g., IRC Section 482) in its tax administration, but specific adjustments can occur when determining the Minnesota portion of a combined group's income, especially regarding sales factor apportionment under Minn. Stat. § 290.17. Companies must ensure their intercompany pricing supports the economic substance of transactions as they relate to Minnesota sourcing and income allocation.