13. How is a unitary relationship determined?
A unitary relationship exists when a taxpayer has control over the entities and the entities have a flow of value between their various operations. Factors that establish a flow of value include:
- Economic realities
- Functional integration
- Centralized management
- Economies of scale
- Substantial mutual interdependence
These factors are not exhaustive or exclusive and the ability to elect combined apportionment will depend on the totality of the circumstances.