We're tracking 3 live transfer pricing roles in Tennessee.
Not enough pay data yet — salary snapshot appears once more roles report bands.


Transfer pricing in the Tennessee context refers to the pricing of transactions between related entities for goods, services, or intellectual property, primarily impacting how income and expenses are reported for Tennessee corporate franchise and excise tax purposes. Although there are no specific state transfer pricing rules, the federal arm's length standard influences how multinational corporations allocate income that ultimately flows through to state tax filings.
Tennessee levies a Franchise Tax based on net worth (or the book value of real & tangible property in TN, whichever is greater) and an Excise Tax on net earnings at a rate of 6.5%. The proper allocation of intercompany charges can significantly affect the Tennessee apportioned income. While there is no specific Tennessee transfer pricing regime, the Tennessee Department of Revenue (TDOR) expects taxpayers to comply with federal income tax rules, including IRC Section 482 for intercompany transactions, when determining taxable income subject to apportionment. Non-arm's length transactions can lead to adjustments impacting the state's tax base.