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Transfer pricing in Texas involves establishing arm's length prices for transactions between related entities operating within and outside the state. While Texas does not have a specific state-level transfer pricing regulatory framework, federal transfer pricing rules under IRC Section 482 directly impact the apportionment and allocation of income for Texas franchise tax purposes.
Texas imposes a franchise tax on entities doing business in Texas, based on the taxable entity's margin. The margin is calculated in several ways, including total revenue less cost of goods sold, or total revenue less compensation. Federal transfer pricing adjustments can significantly impact a Texas company's gross receipts and cost of goods sold, thereby affecting its Texas franchise tax liability. The Texas Comptroller of Public Accounts oversees the administration of the franchise tax.