AZ HB2491

Eliminates the single-sales-factor election for corporate income tax apportionment after December 31, 2026, requiring businesses to use the traditional four-factor formula (property, payroll, and double-weighted sales) instead.

Establishes new market-based sourcing rules for sales of intangible property and services for taxable years beginning after December 31, 2026, assigning income based on where customers receive the benefit rather than where income-producing activity occurs.

Creates detailed rules for determining the location of various income types, including real property rentals, loans secured by real property, investment income, and intangible property licensing.

Maintains existing apportionment options for multistate service providers through December 31, 2026, allowing election of market-based sourcing with a five-year binding commitment.

Retains special revenue-mile-based apportionment rules for taxpayers deriving 50% or more of gross income from air commerce.