Tax insight

Kansas adopts single sales factor, market-based sourcing, and potential rate decreases

  • Insight
  • 5 minute read
  • May 29, 2025

What happened?

Legislation enacted in Kansas includes mandatory single sales factor apportionment and market-based sourcing for sales of other than tangible personal property, applicable to both corporations and pass-through entities such as partnerships. The legislation also provides for potential tax rate reductions depending on levels of state revenue.   

[H.B. 2231, enacted 4/11/2025; S.B. 269, veto overridden, 4/10/2025]

Why is it relevant?

Kansas not only is changing from three-factor apportionment to a single sales factor and adopting market-based sourcing but also is providing a “deferred tax deduction” to account for an increase in a taxpayer’s net deferred tax liability or a decrease in a taxpayer’s net deferred tax asset resulting from the switch to single sales factor apportionment.

Actions to consider

Affected taxpayers should consider changes to their sourcing methodologies and whether a deferred tax deduction may be applicable due to the switch to single sales factor apportionment. Further, taxpayers should monitor revenue announcements that could trigger tax rate changes.

Kansas adopts single sales factor, market-based sourcing, and potential rate decreases

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Ed Geils

Ed Geils

Global and US Tax Knowledge Management Leader, PwC US

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