HAR § 18-237-8.6-02 — Allocation of gross income and gross proceeds from sales of tangible personal property

Except as provided in this section, the gross income and gross proceeds of sale derived from a taxpayer’s sale of tangible personal property shall be allocated to the taxation district where the property is delivered, regardless of where the title to the property passes. Example 1: Taxpayer, a retailer located in the Oahu district, receives an order for products from Purchaser. Taxpayer accepts the order and delivers the products to the Maui district. Taxpayer shall allocate the gross income from the sale to the Maui district, where the products were delivered. Example 2: Taxpayer, a retailer located in the Maui district, sells products to Purchaser located in the Oahu district. Pursuant to Purchaser’s instructions, Taxpayer directs Taxpayer’s product manufacturer, who is located in the Kauai district, to deliver the products to Purchaser’s office in the Maui district. Taxpayer shall allocate the gross income from the sale to the Maui district, where the products were delivered. Example 3: Retailer, located out of state, sells and delivers products to Purchaser in the Oahu district. Retailer shall allocate the gross income from the sale to the Oahu district, where the products were delivered.