IDAPA 35.01.01.341 — PRINCIPLES FOR DETERMINING THE EXISTENCE OF A UNITARY BUSINESS:

DETERMINATION OF A UNITARY BUSINESS (RULE 341).
Section 63-3027, Idaho Code
01.
In General. Unity can be established under any one (1) of the judicially acceptable tests (Butler
Brothers, Edison California Stores, Container, etc.), and cannot be denied merely because another of those tests does
not simultaneously apply.
(4-6-23)
IDAHO ADMINISTRATIVE CODE
IDAPA 35.01.01
Idaho State Tax Commission
Income Tax Administrative Rules
Section 342
Page 55
02.
Significant Flows of Value. A unitary business is characterized by significant flows of value
evidenced by factors such as those described in Mobil Oil Corp. v. Vermont, 445 U.S. 425 (1980): functional
integration, centralization of management, and economies of scale. These factors provide evidence of whether the
business activities operate as an integrated whole or exhibit substantial mutual interdependence. Facts suggesting the
presence of the factors mentioned above should be analyzed in combination for their cumulative effect and not in
isolation. A particular business operation may be suggestive of one (1) or more of the factors mentioned above.
(4-6-23)