Pennsylvania Add-Back For Intangible Expenses or Cost and Related Interested

Add-Back For Intangible Expenses or Cost and Related Interested
Schedule C-6 - Add-Back for Intangible Expenses or Cost and Related Interest (REV-802)
IMPORTANT: FILL IN FORM MUST BE DOWNLOADED ONTO YOUR COMPUTER PRIOR TO COMPLETING

FILL IN FORM USING ALL CAPS. DO NOT USE DASHES (-) OR SLASHES (/) IN ANY FIELD. ENTER DATES AS MMDDYYYY. USE WHOLE DOLLARS ONLY.

REV-802

(SU) 09-22

8020022105

SCHEDULE C-6
ADD-BACK FOR INTANGIBLE EXPENSES OR COST AND RELATED INTEREST

START

➜

Corporation Name
FEIN

Revenue ID

Tax Year Ending

Tax Year Beginning

PAYMENTS MADE DIRECTLY OR INDIRECTLY TO AN AFFILIATED ENTITY

SECTION I

Affiliated Entity Name

FEIN

Where Organized

Where Managed
and Directed
(Corporate HQ)

Intangible
Expenses

Related
Interest Expense

1.

1a.

1b.

2.

2a.

2b.

3.

3a.

3b.

4.

4a.

4b.

5. TOTAL PAYMENTS

5a.

5b.

6. Tax avoidance was not principal purpose and was done at arm's length rates and terms.

6a.

6b.

7. Affiliated entity domiciled in a foreign nation that has in force a comprehensive income tax
treaty with the U.S. Government. (Complete Part II.)

7a.

7b.

8. Affiliated entity was a conduit for the intangible expenses or cost/related interest paid
directly or indirectly by the taxpayer to an unaffiliated entity. (Complete Part III.)

8a.

8b.

9. Total Amount Excluded from Total Intangible Expenses or Cost/Related Interest Payments

9a.

9b.

10a.

10b.

Exclusion of payments:

10. Add-back of Intangible Expenses or Cost/Related Interest Payments
11. TOTAL INTANGIBLE EXPENSES AND RELATED INTEREST EXPENSE

11.

TRANSACTIONS WITH FOREIGN ENTITIES

SECTION II

Foreign Affiliated Entity Name

Domestic Country of Domestic Affiliate
Foreign Affiliate
FEIN

Intangible
Expenses

Related
Interest Expense

1.

1a.

1b.

2.

2a.

2b

3.

3a.

3b.

4.

4a.

4b.

5. TOTAL EXCLUDED

5a.

5b.

8020022105

8020022105
Reset Entire Form

TOP OF PAGE

PAGE 1

NEXT PAGE

PRINT

IMPORTANT: FILL IN FORM MUST BE DOWNLOADED ONTO YOUR COMPUTER PRIOR TO COMPLETING

FILL IN FORM USING ALL CAPS. DO NOT USE DASHES (-) OR SLASHES (/) IN ANY FIELD. ENTER DATES AS MMDDYYYY. USE WHOLE DOLLARS ONLY.

8020022205
REVENUE ID
REV-802 (SU) 09-22

SECTION III

TRANSACTIONS WITH UNAFFILIATED ENTITIES

1. Unaffiliated Entity Name

Affiliated Entity FEIN

a. Intangible Expenses Paid to Unaffiliated Entity

Intangible
Expenses or Cost
1a.

b. Related Interest Expense Paid to Unaffiliated Entity
c/d.

1b.

Total Payment Portion Allocation Percentage

e/f. Exclusion Amount
2. Unaffiliated Entity Name

Related Interest
Expense or Cost

Affiliated Entity FEIN

a. Intangible Expenses Paid to Unaffiliated Entity

1c.

1d.

1e.

1f.

Intangible
Expenses or Cost

Related Interest
Expense or Cost

2a.

b. Related Interest Expense Paid to Unaffiliated Entity

2b.

c/d. Total Payment Portion Allocation Percentage

2c.

2d.

e/f. Exclusion Amount

2e.

2f.

3. Unaffiliated Entity Name

Affiliated Entity FEIN

a. Intangible Expenses Paid to Unaffiliated Entity

Intangible
Expenses or Cost

Related Interest
Expense or Cost

3a.

b. Related Interest Expense Paid to Unaffiliated Entity

3b.

c/d. Total Payment Portion Allocation Percentage

3c.

3d.

e/f. Exclusion Amount

3e.

3f.

4. Unaffiliated Entity Name

Affiliated Entity FEIN

a. Intangible Expenses Paid to Unaffiliated Entity

Intangible
Expenses or Cost

Related Interest
Expense or Cost

4a.

b. Related Interest Expense Paid to Unaffiliated Entity

4b.

c/d. Total Payment Portion Allocation Percentage

4c.

4d.

e/f. Exclusion Amount

4e.

4f.

5. Unaffiliated Entity Name

Affiliated Entity FEIN

a. Intangible Expenses Paid to Unaffiliated Entity

Intangible
Expenses or Cost

Related Interest
Expense or Cost

5a.

b. Related Interest Expense Paid to Unaffiliated Entity

5b.

c/d. Total Payment Portion Allocation Percentage

5c.

5d.

e/f. Exclusion Amount

5e.

5f.

6a.

6b.

6. TOTAL EXCLUDED

8020022205

8020022205
Reset Entire Form

PREVIOUS PAGE

PAGE 2

NEXT PAGE

PRINT

Instructions for REV-802

Add-Back For Intangible Expenses Or Costs & Related Interest Expense

REV-802 IN (SU) 09-22

GENERAL INFORMATION
PURPOSE OF SCHEDULE
For taxable years beginning after December 31, 2014,
corporations are required to add back certain deductions
taken on the federal return for interest, royalties and other
expenses (referred to as intangible expenses) related to
intangible property such as trademarks and patents that
were paid, accrued or incurred directly or indirectly with one
or more affiliated entities. This schedule is used to calculate
the required add-back to federal taxable income for
intangible or related interest expenses.

WHO MUST FILE
Corporations that entered into transactions with an
affiliated entity for the payment of intangible expenses as
defined in 72 P.S. § 7401(8) or interest expense as defined
in 72 P.S. 7401(9) must file this schedule to report those
expenses.

WHEN TO FILE
This schedule must be filed at the same time the
corporation files its RCT-101, PA Corporate Net Income Tax
Report.

WHERE TO FILE
This schedule must be submitted with RCT-101 and with
REV-803, Schedule C-7, Credit for Tax Paid by Affiliated
Entities, if applicable.
Corporations must report all payments for intangible or
related interest expenses in Part I of Schedule C-6, even if
an exception is claimed with respect to such amount.
Allowable exceptions should be reported on Part I, Lines 6,
7 and 8. Failure to properly complete Schedule C-6 may
result in disallowance of claimed exceptions.

COMPLETING PA SCHEDULE C-6
CORPORATION NAME
Enter the complete name of the corporation as shown on
the RCT-101, PA Corporate Net Income Tax Report.
REVENUE ID
Enter the 10-digit Revenue ID number of the corporation as
shown on RCT-101. The Revenue ID is a unique 10-digit
number assigned by the Department of Revenue.

FEIN
Enter the 9-digit FEIN number of the corporation as shown
on RCT-101.
TAX YEAR BEGINNING AND TAX YEAR ENDING
Enter the tax year beginning and tax year ending as shown
on RCT-101.

LINE INSTRUCTIONS
SECTION I
PAYMENTS MADE DIRECTLY OR INDIRECTLY TO AN
AFFILIATED ENTITY
This form allows for the listing of up to four transactions
with four affiliated entities. In the event that the corporation
has more than four transactions with four affiliated entities,
in any combination, a photocopy of this schedule should be
used.

LINE 1 - 4
List the name of each affiliated entity and Federal Employer
Identification Number (FEIN) for which the corporation
accrued or incurred intangible or related interest expenses.
This information must be provided even if the corporation
believes it is subject to a statutory exception. The statutory
exceptions must be claimed on Parts II and III and
summarized on Lines 6 – 8 of Part I.
List by state(s) where the affiliated entities were
incorporated or organized as legal entities and where the
affiliated entities maintain their commercial domicile.
Commercial domicile is the location where a corporation is
managed or directed, the operational headquarters for the
entity.

LINE 5A
Enter the total payments for intangible expenses with
affiliated entities by adding Lines 1a - 4a.

LINE 5B
Enter the total payments for related interest expenses with
affiliated entities by adding Lines 1b - 4b.

www.revenue.pa.gov
PREVIOUS PAGE

REV-802
NEXT PAGE

PRINT

1

LINE 6A

LINE 11

Enter the amount of intangible expenses or costs paid or
incurred to affiliated entities in which tax avoidance was not
a principal purpose and was done at arm’s length rates and
terms.

Enter the total intangible expenses and related interest
expense by adding Lines 10a and 10b. Carry the total to
RCT-101, Section C, Line 3C.

LINE 6B
Enter the amount of related interest expense or cost paid to
affiliates in which tax avoidance was not a principal
purpose and was done at arm’s length rates and terms.

LINE 7A
Enter the related intangible expenses paid to an affiliated
entity domiciled in a foreign nation that has in force a
comprehensive income tax treaty with the U.S.
Government from Part II, Line 5a.

LINE 7B

SECTION II
TRANSACTIONS WITH FOREIGN ENTITIES
Part II is for providing intangible or related interest
expenses or costs paid or accrued to an affiliated entity that
is excluded by reason that the transaction was directly or
indirectly between the taxpayer and an affiliated entity
domiciled in a foreign nation which has in force a
comprehensive income tax treaty with the United States.
These treaties provide for the allocation of all categories of
income subject to taxation, or the withholding of tax, on
royalties, licenses, fees and interest for the prevention of
double taxation of the respective nations' residents and the
sharing of information.

Enter the related interest expense paid to an affiliated entity
domiciled in a foreign nation that has in force a
comprehensive income tax treaty with the U.S.
Government from Part II, Line 5b.

This form allows for the listing of up to four transactions
with four affiliated entities. In the event that the taxpayer
has more than four transactions with four affiliated entities,
in any combination, a photocopy of this schedule should be
used.

LINE 8A

LINES 1-4

Enter the related intangible expenses paid to an affiliated
entity who acted as a conduit of the expense paid to an
unaffiliated entity from Part III, Line 6a.

Enter the name of each foreign affiliated entity for which
this exception applies. Enter the country of domicile of the
foreign affiliated entity. If the expenses were paid through a
domestic affiliate, enter the FEIN of the domestic affiliated
entity. Enter the total intangible expenses or cost or related
interest expense to each foreign affiliated entity.

LINE 8B
Enter the related interest expense paid to an affiliated entity
who acted as a conduit of the expense paid to an
unaffiliated entity from Part III, Line 6b.

LINE 9A
Enter the total amount of excluded intangible expenses by
adding Lines 6a - 8a.

LINE 9B
Enter the total amount of excluded related interest expense
by adding Lines 6b - 8b.

LINE 10A
Enter the intangible expenses required to be added back to
federal taxable income by subtracting Line 9a from Part I,
Line 5a.

LINE 10B
Enter the related interest expense required to be added
back to federal taxable income by subtracting Line 9b from
Part I, Line 5b.
2

LINE 5A
Enter the total intangible expenses or cost paid to each
foreign affiliated entity covered by tax treaty by adding Part
II, Lines 1a - 4a. Carry total to Part I, Line 7a.

LINE 5B
Enter the total related interest expense or cost paid to each
foreign affiliated entity covered by tax treaty by adding Part
II, Lines 1b - 4b. Carry total to Part I, Line 7b.

SECTION III
TRANSACTIONS WITH UNAFFILIATED ENTITIES
Part III is for providing intangible expenses or cost or
related interest excluded by reason that the affiliated entity
that received the payment had directly or indirectly paid,
accrued or incurred payment to an unaffiliated entity. The
payment to the unaffiliated entity is paid, accrued or
incurred on the intangible expense or cost or related
interest, and is equal to or less than the taxpayer's
proportional share of the transaction. The taxpayer's

REV-802

www.revenue.pa.gov

PREVIOUS PAGE

NEXT PAGE

PRINT

proportional share shall be based on relative sales, assets,
liabilities or another reasonable method.
This form allows for the listing of up to five transactions with
five affiliated entities. In the event that the taxpayer has
more than five transactions with five affiliated entities, in
any combination, a photocopy of this schedule should be
used.
UNAFFILIATED ENTITY NAME AND AFFILIATED
ENTITY FEIN
Enter the name of the unaffiliated entity or outside party
that received the related interest or intangible expenses or
cost from the affiliated entity (conduit). Enter the FEIN of
the affiliated entity, from Part I, that was the conduit.

LINE A
Enter the amount of intangible expenses or cost paid to the
unaffiliated entity. The amount paid should be equal to or
less than the taxpayer’s proportional share of the
transaction.

LINE B
Enter the amount of related interest expense or cost paid to
the unaffiliated entity. The amount paid should be equal to
or less than the taxpayer’s proportional share of the
transaction.

LINE C/D
It is possible that the conduit or affiliated entity charged the
taxpayer a mark-up for the transaction, and that the
conduit/affiliated entity may have been a conduit for other
transactions between other entities affiliated with the
taxpayer and the outside party. The amount of intangible
expenses or cost or related interest that went from the
affiliated entity to the outside party may be greater than the
actual amount of intangible expenses or cost or related
interest transacted by the taxpayer for the outside party.
The amount of exception cannot exceed the actual amount
paid to the outside party for the taxpayer’s use of the

intangible property. All mark-ups to the conduit/affiliated
entity must be excluded, and all amounts for transactions
from other affiliated entities must be excluded. In the event
that the amount(s) between the taxpayer and outside party
were not segregated from the mark-ups and other
transactions, the exception shall be computed using a ratio
or percentage based on the relative sales/receipts for the
intangible expenses or cost or related interest, or assets, or
liabilities or another reasonable method. The taxpayer
should indicate on this form if the actual segregated
amount(s) were used, or pro-rations using receipts, assets,
liabilities or another reasonable method were used, and
attach a schedule showing the computations.
Enter the percentage used to allocate the portion of the
total payments that are related specifically to the use of the
intangible property by the taxpayer, exclusive of any
markups by the conduit/affiliated entity. Attach a statement
describing the computation used to calculate the exclusion
percentage.

LINE E
Enter the exclusion amount for intangible expenses or cost
by multiplying Line a by Line c.

LINE F
Enter the exclusion amount for related interest expense or
cost by multiplying Line b by Line d.

LINE 6A
Enter the total intangible expenses or cost excluded by
adding Part III, Lines 1e - 5e. Carry total to Part I, Line 8a.

LINE 6B
Enter the total related interest expense or cost excluded by
adding Part III, Lines 1f - 5f. Carry total to Part I, Line 8b.

www.revenue.pa.gov
PREVIOUS PAGE

REV-802
RETURN TO PAGE 1

PRINT

3