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.