How to compute FL Corporate Income Tax for Florida, tax year 2025: rates, thresholds, and step-by-step rules with primary-source citations.
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General tax imposition
Tax is imposed on the Florida net income of every taxpayer doing business in Florida, deriving income from sources in Florida, or existing with a nexus to Florida sufficient to create a constitutional taxing jurisdiction. "Taxpayer" means a corporation subject to the tax.s. 220.11, F.S.; s. 220.03(1)(z), F.S.
C-corporations
C-corporations organized under the laws of Florida or any other jurisdiction, doing business in Florida, are subject to the tax.s. 220.11, F.S.
LLCs electing C-corp status
LLCs that have elected to be taxed as a C-corporation for federal purposes (Form 8832 election to be treated as an association taxable as a corporation, or a deemed corporation election triggered by an S-election that is invalid) file F-1120 in the same manner as any other C-corp.s. 220.11, F.S.
Foreign C-corporations nexus
Foreign (out-of-state) C-corporations with sufficient nexus under s. 220.11, F.S. and Florida's economic nexus jurisprudence are subject to the tax. Florida has not enacted a bright-line economic nexus statute for corporate income tax, but physical presence, employees, or property in Florida triggers nexus.s. 220.11, F.S.
Banks and savings associations
Banks and savings associations are subject under s. 220.63, F.S. (outside the scope of this skill).s. 220.63, F.S.
Sole proprietorships
Florida Corporate Income/Franchise Tax under Chapter 220, Florida Statutes, applies to C-corporations doing business in Florida at a 5.5% rate on apportioned Florida net income, after a $50,000 exemption. Apportionment uses a three-factor formula with double-weighted sales (property + payroll + 2x sales / 4) and cost-of-performance sourcing for services. Filed on Form F-1120. Florida has no personal income tax, so sole proprietors, partnerships, LLCs taxed as partnerships, and S-corporations generally owe no Florida income tax on operating income. Tax year 2025.
This skill covers the Florida Corporate Income/Franchise Tax imposed under Chapter 220 of the Florida Statutes for tax year 2025. It addresses:
This skill does NOT cover:
This skill assumes the user is a sole proprietor, single-member LLC, multi-member LLC, partnership, S-corp, or small C-corp filing a Florida return. It is not designed for large multistate consolidated groups, REITs, regulated investment companies, or insurance companies.
Florida is one of nine states with no state-level personal income tax. The prohibition is constitutional: Art. VII, s. 5 of the Florida Constitution provides that no tax upon income shall be levied by the state upon natural persons. The Florida corporate income tax, enacted by Ch. 220 in 1971 following a constitutional amendment authorizing it, applies only to corporations and not to individuals, partnerships, or other pass-through entities.
The practical effect for the typical OpenAccountants user base is:
Historical effective rates table (TIP 19C01-04; TIP 20C01-01; TIP 21C01-01; TIP 22C01-01; TIP 22C01-02; s. 220.11, F.S.)
| Tax year | Effective rate | Source |
|---|---|---|
| 2018 | 4.458% | TIP 19C01-04, FL DOR |
| 2019 | 4.458% | TIP 20C01-01, FL DOR |
| 2020 | 3.535% | TIP 21C01-01, FL DOR |
| 2021 | 3.535% | TIP 22C01-01, FL DOR (retroactive adjustment) |
| 2022 | 5.5% (rate restored) | TIP 22C01-02, FL DOR |
| 2023 | 5.5% | s. 220.11, F.S. |
| 2024 | 5.5% | s. 220.11, F.S. |
| 2025 | 5.5% | s. 220.11, F.S. |
Florida is one of a shrinking number of states still using a property-and-payroll-inclusive apportionment formula. Most states have moved to single-sales-factor apportionment over the past two decades. Florida's continued use of three-factor double-weighted-sales is a quirk that catches out-of-state preparers.
This matters enormously for software developers, consultants, and other service businesses. A Florida-based C-corp that performs services entirely in Florida sources 100% of its service receipts to Florida, even if all customers are out of state. Conversely, a non-Florida C-corp that has Florida customers but performs the work elsewhere sources 0% to Florida.
Compare this to California (market-based sourcing — service receipts sourced to the customer's location), New York (market-based for most services since 2015), or Massachusetts (market-based since 2014). The contrast can produce dramatic differences in apportionment percentages.
Florida has resisted the trend toward market-based sourcing for over a decade despite repeated legislative proposals (e.g., HB 7129 in 2019, HB 7079 in 2021 — both failed). For tax year 2025, the rule remains cost-of-performance.
Installment due dates (s. 220.34, F.S.)
| Installment | Due date | % of total |
|---|---|---|
| 1st | May 31 (last day of 5th month of tax year) | 25% |
| 2nd | June 30 (last day of 6th month) | 25% |
| 3rd | September 30 (last day of 9th month) | 25% |
| 4th | January 31 of following year (last day of tax year + 1 month) | 25% |
Florida offers a modest set of corporate income tax credits, most of which are narrow and not applicable to typical small C-corps.
This contrasts with, for example, Texas (franchise tax / margin tax separate from federal income tax), Delaware (annual franchise tax based on authorized shares plus a separate corporate income tax), and California ($800 minimum franchise tax plus 8.84% corporate income tax).
The only annual maintenance fee paid to the state for a Florida corporation is the annual report fee to the Florida Department of State, Division of Corporations ($150 for for-profit corporations, $138.75 for LLCs). This is filed via Sunbiz.org by May 1 each year. It is NOT a tax — it is a corporate maintenance fee and is not addressed by this skill.
Florida documentary stamp tax (Ch. 201, F.S.) is a separate tax on:
Doc stamp is collected at the county recorder's office (for real estate) or paid via Form DR-225 (for notes not recorded). It is NOT a corporate income tax matter and is outside the scope of this skill. Refer the client to a Florida real estate attorney or title agent.
This is by far the most frequent error among out-of-state preparers and software-driven services. A Florida single-member LLC that has NOT elected to be taxed as a corporation:
The LLC's only Florida obligations are:
If you see a Florida SMLLC owner asking "do I file F-1120?", the answer is no, unless they affirmatively elected C-corp treatment via Form 8832.
An S-corp with only ordinary pass-through income (federal Form 1120-S, no built-in gains, no LIFO recapture, no §1375 tax) is NOT required to file Florida F-1120 because it has zero federal taxable income at the entity level. Some preparers reflexively file a zero-tax F-1120; this is unnecessary and clogs the DOR's records. Do not file unless required.
Florida uses COST-OF-PERFORMANCE sourcing. A preparer trained on California, New York, or Massachusetts (all market-based) will instinctively source receipts to the customer location. This produces a wrong Florida apportionment. Always read s. 220.15(5)(b), F.S. and Rule 12C-1.0155, F.A.C., and source based on where the income-producing activity is performed.
Some preparers, unfamiliar with Florida, default to single-sales-factor (which is now the majority state approach). Florida is three-factor with double-weighted sales (P + Pa + 2S / 4). Always verify the formula.
The $50,000 is a deduction from Florida net income, not a credit against tax. It saves 5.5% × $50,000 = $2,750 of Florida tax for a profitable corporation, not $50,000.
Florida disallows the federal NOL and substitutes its own Florida NOL. Always add back the federal NOL on Schedule II and compute Florida NOL separately on Schedule IV.
Florida decouples from IRC §168(k) bonus depreciation. The federal bonus depreciation must be added back and depreciated over seven years for Florida purposes. With federal bonus phasing back up to 100% under OBBBA for property placed in service after January 19, 2025, this addback is again material for 2025 returns.
A Florida extension requires payment of tentative tax. An extension filed without payment is invalid, and the corporation is treated as a late filer from the original due date. This is harsher than the federal rule (where an extension without payment is still a valid extension to file, just not to pay).
If amending a 2020 or 2021 return, the effective rate was 3.535% (TRIM Act). Do not use 5.5%. For 2022 and forward, use 5.5%.
Nexus is based on where the corporation does business, not where it is incorporated. A Delaware C-corp with all operations in Florida files F-1120. A Florida-incorporated C-corp with all operations in Texas owes no Florida tax (unless it has Florida nexus through some residual activity).
Facts. SunCode Inc., a Florida C-corporation, develops custom software for clients nationwide from its sole office in Tampa. All employees (10 W-2 developers, 1 owner-CEO) work from the Tampa office. All R&D, project management, and customer support is performed in Florida. Customers are located in 35 states; about 12% of revenue comes from Florida customers, 88% from out-of-state customers.
For tax year 2025:
Step 1 — Federal taxable income. $480,000.
Step 2 — Florida additions. Add back federal bonus depreciation: +$30,000.
Step 3 — Florida subtractions. Reverse prior bonus depreciation addback: ($5,000).
Step 4 — Adjusted federal income. $480,000 + $30,000 - $5,000 = $505,000.
Step 5 — Apportionment.
Property factor. All property is in Tampa. Numerator = $50,000 average cost. Denominator = $50,000. Property factor = 100%.
Payroll factor. All employees in Tampa. Numerator = $1,200,000. Denominator = $1,200,000. Payroll factor = 100%.
Sales factor. All services performed in Florida. Under cost-of-performance, 100% of service receipts are sourced to Florida — even though 88% of customers are out of state. Numerator = $3,500,000. Denominator = $3,500,000. Sales factor = 100%.
Apportionment %. (100% + 100% + 2 × 100%) / 4 = 400% / 4 = 100%.
Step 6 — Florida apportioned income. $505,000 × 100% = $505,000.
Step 7 — $50,000 exemption. $505,000 - $50,000 = $455,000.
Step 8 — Florida tax at 5.5%. $455,000 × 5.5% = $25,025.
Step 9 — Estimated payments. Since $25,025 > $2,500, quarterly estimated payments required for 2026.
Filing. Form F-1120 due May 1, 2026 (calendar year 2025).
Commentary. Despite serving customers in 35 states, SunCode is 100% Florida-apportioned because Florida uses cost-of-performance and all the work is done in Tampa. If the same company were headquartered in California (market-based sourcing), only 12% of receipts would be California-sourced. This is the cost-of-performance trap for Florida service businesses serving national customers — it concentrates tax in Florida.
Facts. TechFlow Inc., a Delaware C-corporation headquartered in Boston, Massachusetts, provides cloud-based SaaS to customers nationwide. All servers, employees, and operations are in Massachusetts. Florida customers generate $800,000 of annual revenue out of $10,000,000 total revenue. TechFlow has no Florida employees, no Florida property, and no Florida office.
For tax year 2025:
Nexus analysis. TechFlow has no physical presence in Florida. Florida has not enacted a bright-line economic nexus statute for corporate income tax (unlike for sales tax). Whether TechFlow has Florida CIT nexus depends on the specific facts and constitutional limits. Conservative position: if TechFlow has substantial Florida customers, P.L. 86-272 might not protect it because P.L. 86-272 only protects solicitation of orders for tangible personal property, not services or SaaS. However, without physical presence, the case for Florida nexus is weak.
Decision. TechFlow likely has no Florida CIT filing obligation. No F-1120 filed.
Counterfactual. If TechFlow had a single Florida employee (a remote sales rep), nexus would clearly exist, and TechFlow would file F-1120.
If TechFlow were subject to Florida CIT:
Sales factor (cost-of-performance). All service activity is performed in Massachusetts. Florida sales numerator = $0 (none of the income-producing activity is in Florida). Florida sales factor = 0%.
Property factor. 0% (no Florida property). Payroll factor. 0% (no Florida payroll). Apportionment %. (0 + 0 + 2 × 0) / 4 = 0%.
Florida apportioned income. $2,000,000 × 0% = $0. Florida tax. $0.
Even if a return is filed defensively, the tax would be $0. This is the inverse of Example 1 — under cost-of-performance, out-of-state service providers with Florida customers owe nothing.
Commentary. Florida's cost-of-performance sourcing rewards out-of-state service providers and disadvantages in-state ones, relative to a market-based regime. Tax planners with mobility have, over the years, used this asymmetry to locate service operations outside Florida while serving Florida customers — but the corollary is that in-state C-corps face high Florida concentration.
Facts. Maria Santos operates "Coral Reef Consulting LLC," a Florida single-member LLC formed in 2023. The LLC has not filed Form 8832 to elect corporate treatment. Maria is the sole owner and reports all LLC income on her Schedule C. For 2025:
Florida obligations.
Total Florida state-level tax burden: $0.
Commentary. This is why Florida is so attractive to freelancers and single-member LLC owners. A New York or California freelancer with the same $145,000 federal income pays an additional ~$8,500–$12,000 in state income tax. The Florida equivalent pays only the $138.75 annual report fee.
This is also why Florida is the wrong place to consider an S-corp election purely for state tax savings — there are no state-level SE tax savings to capture (because there's no state SE tax to begin with). Federal SE tax savings still motivate the S-corp election for high-earning Florida sole proprietors, but the analysis is purely federal. See the us-s-corp-election-decision skill.
Facts. Atlantic Manufacturing Inc., a Florida C-corp, projects a 2025 Florida tax liability of $40,000. The CEO wants to redirect tax dollars to Step Up For Students (an approved SFO) to fund private school scholarships for low-income students.
Steps.
Net effect. Atlantic pays $40,000 to Step Up For Students instead of $40,000 to the FL DOR. Federal tax position is neutral or improved (depending on prior year tax position). Florida tax is $0. The contribution funds private school scholarships for low-income students at no net cost to Atlantic.
Commentary. This credit is the most popular Florida corporate income tax credit because it is a true dollar-for-dollar tax-to-contribution redirection. It works particularly well for C-corps that would otherwise have a Florida tax liability between $10,000 and $500,000.
Facts. GulfCoast Logistics Inc., a Florida C-corp, operates trucking and warehousing services in Florida, Georgia, and Alabama. For 2025:
Apportionment.
Property factor. $2,000,000 / $2,800,000 = 71.43%. Payroll factor. $4,000,000 / $5,400,000 = 74.07%. Sales factor (cost-of-performance). $6,000,000 / $8,200,000 = 73.17%.
Note: GulfCoast may be eligible for transportation-specific apportionment under s. 220.151, F.S. (mileage-based), but for illustration we use standard apportionment.
Apportionment %. (71.43% + 74.07% + 2 × 73.17%) / 4 = (71.43 + 74.07 + 146.34) / 4 = 291.84% / 4 = 72.96%.
Florida apportioned income. $1,200,000 × 72.96% = $875,520.
$50,000 exemption. $875,520 - $50,000 = $825,520.
Florida tax at 5.5%. $825,520 × 5.5% = $45,404.
Commentary. The double-weighting of sales means the sales factor effectively determines ~50% of the apportionment. Because Florida uses cost-of-performance, the $6M of services originating from Florida warehouse all source to Florida. If Florida used market-based sourcing, the answer might be quite different depending on customer locations.
The corporation would also file Georgia and Alabama corporate income tax returns. Total state tax across the three states is unlikely to sum to 100% because each state uses its own apportionment formula — possible double tax or apportionment gaps.
Before signing off on an F-1120:
Version 0.1, pending review by a Florida-credentialed reviewer (CPA or licensed Florida attorney). Last updated 2025-11-15. Confirm the IRC conformity date and any 2025 legislative changes against the FL DOR website (floridarevenue.com/taxes/taxesfees/Pages/corporate.aspx) and the most recent F-1120 instructions before signing off on a 2025 return.
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Review status
Accountant-reviewed
Reviewed by a named licensed practitioner against the stated sources, as general reference material.
Accountant-reviewed
Reviewed by Rob Hoffman · 25 June 2026
A named accountant reviewed this complete Guide version within the stated scope. It is not a guarantee.
View review record →Other Florida computations in the OpenAccountants Tax Library.
Florida has no personal income tax. A self-employed individual operating as a sole proprietor pays no Florida income tax on Schedule C profits, no Florida tax on self-employment earnings, and no Florida tax on wages. The individual files only the federal Form 1040 and Schedule C/SE.Florida has no personal income tax
Single-member LLCs disregarded
Because the SMLLC is disregarded under Treas. Reg. §301.7701-3 and reports on Schedule C of the owner's Form 1040, the SMLLC has no separate federal return and accordingly no Florida F-1120 filing obligation. Florida follows the federal classification.s. 220.03(1)(e), F.S.; Treas. Reg. §301.7701-3
Multi-member LLCs taxed as partnerships
The LLC files federal Form 1065 and issues K-1s. Florida does not impose an entity-level tax on partnerships or pass-throughs. Florida Form F-1065 (partnership information return) is required only if a partner is a corporation subject to Ch. 220 — most small multi-member LLCs with only individual members do not file F-1065.s. 220.13, F.S.
General and limited partnerships
General and limited partnerships taxed as partnerships federally receive the same treatment as multi-member LLCs.s. 220.13, F.S.
S-corporations
Florida does not impose corporate income tax on income that is taxed at the shareholder level federally. The Florida starting point for an S-corp is the federal taxable income of the S-corp itself, which for pure S-corp income (passing through on Schedule K-1) is generally zero at the entity level. However, an S-corp IS required to file F-1120 if the federal return shows taxable income at the entity level, most commonly: Built-in gains tax under IRC §1374 (if the S-corp pays §1374 tax federally, that built-in gain income flows through as Florida taxable income and the S-corp must file F-1120 reporting the federal taxable income that is subject to Florida tax); LIFO recapture under IRC §1363(d) on conversion from C to S; Excess net passive income tax under IRC §1375. In each case the S-corp files F-1120 reporting only the federally-taxed amount, then claims the $50,000 exemption (which usually wipes out the Florida liability for small S-corps).s. 220.13(2)(k), F.S.; s. 220.13(2), F.S.
Sole proprietors using a single-member LLC
No federal return for the LLC, no Florida return.s. 220.03(1)(e), F.S.
Disregarded entities of any kind
E.g., QSubs of an S-corp, grantor trust-owned LLCs, are not subject to the tax.s. 220.03(1)(e), F.S.
Individuals
Florida has no personal income tax. Art. VII, s. 5, Florida Constitution prohibits state income tax on natural persons without a constitutional amendment, which has not been enacted.Art. VII, s. 5, Florida Constitution
501(c) exempt organizations
Not subject except to the extent they have unrelated business taxable income (UBTI) under IRC §511 — UBTI is subject to Florida corporate income tax starting from federal taxable income on Form 990-T.s. 220.13(1)(a), F.S.; IRC §511
Insurance companies
Insurance companies subject to insurance premium tax are out of scope.out of scope
Florida corporate income tax rate
5.5%s. 220.11(2), F.S.
TRIM Act mechanism
Section 220.1105, F.S. (the "Tax Refund and Rate Reduction Mechanism," sometimes called the TRIM Act) created an automatic rebate-and-rate-reduction mechanism that operated for tax years 2018 through 2021. When net corporate income tax collections exceeded statutory adjusted-revenue baselines, the Department of Revenue was required to: 1. Issue refunds to taxpayers for the prior year's overpayment. 2. Reduce the rate for the following tax year by a downward adjustment.s. 220.1105, F.S.
Historical effective rates table
| Tax year | Effective rate | Source | |---|---|---| | 2018 | 4.458% | TIP 19C01-04, FL DOR | | 2019 | 4.458% | TIP 20C01-01, FL DOR | | 2020 | 3.535% | TIP 21C01-01, FL DOR | | 2021 | 3.535% | TIP 22C01-01, FL DOR (retroactive adjustment) | | 2022 | 5.5% (rate restored) | TIP 22C01-02, FL DOR | | 2023 | 5.5% | s. 220.11, F.S. | | 2024 | 5.5% | s. 220.11, F.S. | | 2025 | 5.5% | s. 220.11, F.S. |TIP 19C01-04; TIP 20C01-01; TIP 21C01-01; TIP 22C01-01; TIP 22C01-02; s. 220.11, F.S.
TRIM Act expiration and 2025 guidance
The TRIM Act mechanism in s. 220.1105 expired on its own terms after the 2021 fiscal year refund. Beginning with tax year 2022, the rate has been the statutory 5.5% with no further automatic rebates. For 2025, use 5.5%. Do not attempt to apply any TRIM Act reduction. If preparing an amended return for a 2020 or 2021 tax year, verify the correct effective rate from the FL DOR Tax Information Publication for that year.s. 220.1105, F.S.
$50,000 exemption
$50,000s. 220.14, F.S.
Florida tax computation mechanics
1. Start with federal taxable income from Form 1120 Line 30 (or Form 1120-S Line 21 for S-corps with federally-taxed income). 2. Apply Florida additions and subtractions per s. 220.13, F.S. to arrive at Florida adjusted federal income. 3. Apportion using the three-factor formula (s. 220.15, F.S.). 4. Add back any nonbusiness income allocated to Florida under s. 220.16, F.S. 5. Subtract the $50,000 exemption (s. 220.14, F.S.). 6. Multiply the result by 5.5% to compute the gross Florida tax. 7. Subtract credits.s. 220.13, F.S.; s. 220.14, F.S.; s. 220.15, F.S.; s. 220.16, F.S.
Below-exemption filing note
If apportioned Florida net income is less than $50,000, no Florida tax is due (but F-1120 may still need to be filed — see Section 7).s. 220.14, F.S.
Short-period proration
The exemption is pro-rated for short-period returns — multiply $50,000 by (number of days in the short period / 365).s. 220.14(2), F.S.
Consolidated returns single exemption
For consolidated returns under s. 220.131, F.S., only one $50,000 exemption is available for the entire consolidated group.s. 220.14(3), F.S.
Florida AMT status
Florida historically imposed an alternative minimum tax tied to the federal corporate AMT. With the federal repeal of the corporate AMT for tax years beginning after December 31, 2017 (TCJA), Florida's AMT effectively went dormant. The federal Corporate Alternative Minimum Tax (CAMT) enacted by the Inflation Reduction Act of 2022 applies to "applicable corporations" with three-year average AFSI of $1 billion or more — this is far outside the scope of small-business Florida filings. For 2025, treat Florida AMT as non-applicable for OpenAccountants's typical small-business taxpayers.s. 220.11(3), F.S.
Rolling conformity
Florida is a "rolling conformity" state for the federal Internal Revenue Code — s. 220.03(2), F.S. ties Florida to the IRC as in effect on January 1 of each year, with the conformity date updated annually by the Legislature. For tax year 2025, the most recent conformity update applies (verify the current piggyback date in the annual Form F-1120 instructions). The Florida tax base starts at federal taxable income — Line 30 of Form 1120, before the federal NOL deduction and before special deductions.s. 220.03(2), F.S.
Principal addbacks
The principal addbacks for a small C-corp are: Federal NOL deduction — Florida disallows the federal NOL deduction (because Florida has its own NOL system). Add back the federal NOL claimed on Line 29a of Form 1120. Federal income tax refund if previously deducted (rare for corporations). Florida intangible tax (now repealed but included for historical adjustments). State income taxes of states other than Florida deducted on the federal return (s. 220.13(1)(a)1., F.S.). Depreciation differences under s. 220.13(1)(e), F.S. — Florida decouples from federal bonus depreciation under IRC §168(k) and from the IRC §179 expensing limits for certain periods. For 2025, verify the current addback rules in the Form F-1120 instructions. Florida historically required addback of 100% of federal bonus depreciation, then allowed it back over seven years. Federal §965 deemed repatriation income addbacks (transition tax) — largely historical now. Interest excluded from federal taxable income under IRC §103 (state and municipal bond interest, except Florida bonds).s. 220.13(1)(a), F.S.; s. 220.13(1)(a)1., F.S.; s. 220.13(1)(e), F.S.
Principal subtractions
Florida NOL carryforward (s. 220.13(1)(b)1., F.S.) — see Section 6. Net operating loss for the year allowed federally but limited federally — Florida applies its own NOL rules. Florida bonus depreciation addback reversal — the seven-year amortization of the addback amount. Interest on US Treasury obligations to the extent included in federal taxable income. Salary and wage adjustment for the federal Work Opportunity Tax Credit — Florida allows a deduction equal to the salary/wages disallowed federally under IRC §280C. Subpart F income exclusions for foreign source income to the extent permitted under s. 220.13(1)(b)2., F.S. GILTI subtraction — Florida treats GILTI (IRC §951A) as subpart F income and follows federal treatment with a partial subtraction; verify current rules in the F-1120 instructions. Foreign-source dividends under s. 220.13(1)(b)2., F.S. that are not eligible for the federal dividends-received deduction.s. 220.13(1)(b), F.S.; s. 220.13(1)(b)1., F.S.; s. 220.13(1)(b)2., F.S.
Adjusted federal income
After additions and subtractions, you have "adjusted federal income" — the Florida pre-apportionment base.s. 220.13, F.S.
Apportionment formula
Apportionment % = (Property factor + Payroll factor + 2 x Sales factor) / 4. Each factor is the Florida-numerator divided by the everywhere-denominator. Sales is weighted 2x (i.e., counts twice), so the total denominator is 4.s. 220.15, F.S.
Property factor mechanics
The property factor is the average value of the corporation's real and tangible personal property owned or rented in Florida, divided by the average value of all such property everywhere. Owned property is valued at original cost (not net book value). Rented property is capitalized at 8 times the annual rent. Inventory is included at its tax-basis value. Idle property that has been actively used in business but is temporarily not in use is included. Construction in progress is generally excluded until placed in service.s. 220.15(3), F.S.
Payroll factor sourcing cascade
The payroll factor is total compensation paid in Florida divided by total compensation paid everywhere. Compensation is sourced to Florida if: 1. The services are performed entirely in Florida; OR 2. The services are performed both in and outside Florida, but the services performed outside are incidental to the services in Florida; OR 3. Some services are performed in Florida and the employee's base of operations is in Florida; OR 4. The employee has no base of operations in any state where services are performed, but the place from which services are directed/controlled is in Florida; OR 5. The base of operations is in no state where any services are performed, and the employee is a Florida resident. This is the standard UDITPA-derived "base of operations" cascade. Independent contractor payments are NOT included in the payroll factor.s. 220.15(4), F.S.
Sales factor and tangible property sourcing
The sales factor is total Florida sales divided by total sales everywhere. For tangible personal property, sales are sourced to Florida if the property is delivered or shipped to a purchaser in Florida, regardless of the FOB point (destination sourcing).s. 220.15(5), F.S.
Cost-of-performance sourcing for services
For services and intangibles, Florida uses cost-of-performance sourcing: A service is sourced to Florida if the income-producing activity is performed entirely in Florida; OR if the income-producing activity is performed in more than one state, the service is sourced to the state where the greater proportion of the income-producing activity is performed, based on costs of performance. This is the "all-or-nothing" cost-of-performance rule (as opposed to "pro-rata cost-of-performance"). The entire receipt goes to one state — whichever state has the highest cost of performance. There is no market-based sourcing in Florida for services.s. 220.15(5)(b), F.S.; Rule 12C-1.0155, F.A.C.
Special apportionment categories
Transportation services (railroads, motor carriers, airlines) — special apportionment formulas under s. 220.151, F.S. Financial organizations (banks, lenders) — special formula under s. 220.15(6), F.S. Insurance companies — separate framework (out of scope). Telecommunications — special rules. Petitions for alternative apportionment under s. 220.152, F.S. — taxpayer or DOR can petition for an alternative method if the standard formula does not fairly represent the extent of the taxpayer's Florida business activity. High burden of proof. Refer out for any alternative apportionment petition.s. 220.151, F.S.; s. 220.15(6), F.S.; s. 220.152, F.S.
Allocation of nonbusiness income
Income that is not "business income" (i.e., income that is not from transactions and activity in the regular course of the taxpayer's trade or business) is allocated rather than apportioned. Common items: Capital gains/losses on nonbusiness assets — allocated to the commercial domicile. Royalties from intangibles — allocated based on the location of use. Dividends — allocated to the commercial domicile. Interest on nonbusiness assets — allocated to the commercial domicile. Rents from nonbusiness real property — allocated to the situs. For most operating C-corps, all income is business income and is fully apportioned. The business/nonbusiness distinction matters mostly for holding companies and investment-heavy entities.s. 220.16, F.S.
Order of operations
1. Federal taxable income (Form 1120 Line 30). 2. Apply Florida additions and subtractions per s. 220.13 → "adjusted federal income." 3. Subtract nonbusiness income (which will be allocated separately) → "apportionable income." 4. Apply the three-factor double-weighted sales apportionment formula → Florida apportioned income. 5. Add Florida-allocated nonbusiness income → Florida net income. 6. Subtract the $50,000 exemption (s. 220.14). 7. Multiply by 5.5% → gross Florida tax. 8. Subtract credits.s. 220.13, F.S.; s. 220.14, F.S.; s. 220.15, F.S.; s. 220.16, F.S.
Post-2017 NOL rules
For NOLs arising in tax years beginning after December 31, 2017, Florida follows the post-TCJA federal framework: 80% of taxable income limitation — The Florida NOL deduction is limited to 80% of Florida taxable income (before the NOL deduction) for the carryforward year. This mirrors IRC §172(a)(2) as amended by TCJA. No carryback — Florida does not permit NOL carrybacks (consistent with federal post-TCJA treatment). Indefinite carryforward — The unused NOL carries forward indefinitely until exhausted (no 20-year limit).IRC §172(a)(2); s. 220.13(1)(b)1., F.S.
Pre-2018 NOL grandfathered rules
NOLs generated in tax years beginning before January 1, 2018 retain their pre-TCJA characteristics: 20-year carryforward limit (so 2017 NOLs expire after 2037). No 80% limitation — they can offset 100% of Florida taxable income. No carryback (Florida never allowed NOL carrybacks). The 80% limitation applies separately to pre- and post-2018 NOLs — pre-2018 NOLs are deducted first, without limitation; then post-2018 NOLs are deducted, subject to 80%.s. 220.13(1)(b)1., F.S.
Florida NOL computation
The Florida NOL is computed on a Florida-only basis. It is NOT the federal NOL. To compute the Florida NOL: 1. Start with adjusted federal income for the loss year. 2. Apply apportionment. 3. The Florida-apportioned loss (after the $50,000 exemption is NOT subtracted in a loss year — the exemption is for income years only) is the Florida NOL. Track each year's NOL separately on the F-1120 Schedule IV. The DOR requires year-by-year carryforward tracking.s. 220.13(1)(b)1., F.S.
IRC §382 conformity
Florida conforms to IRC §382 limitations on NOL utilization following an ownership change. If a federal §382 limit applies, the same limit applies for Florida purposes.IRC §382
NOL suspension on S-election
If a C-corp with NOL carryforwards elects S-corp status, the C-corp NOLs are suspended at the entity level. They can be used to offset any built-in gains tax or other federally-taxed C-corp items that flow into Florida F-1120 (very rare). They cannot pass through to the shareholders.
Filing requirement
Every corporation subject to Florida corporate income tax must file Form F-1120, even if no tax is due. Filing is required if: The corporation is doing business, earning income, or existing in Florida. The corporation files a federal Form 1120, 1120-S (with federally-taxed items), 1120-F, or similar. A corporation with no Florida nexus does not file. A pure pass-through (partnership, S-corp without federally-taxed items, disregarded entity) does not file.
F-1120 due date rule
Form F-1120 is due on or before the first day of the fifth month following the close of the tax year, OR the 15th day after the federal return due date, whichever is later.
Calendar-year due dates for 2025
For calendar-year C-corps: Federal Form 1120 is due April 15, 2026 for tax year 2025. Florida F-1120 is due May 1, 2026 (1st day of the 5th month after Dec 31, 2025). Note: this is one day after the comparable federal extension consideration deadline. The Florida due date is genuinely later than the federal due date, not the same.
Fiscal-year filers due date
For fiscal-year filers: Florida F-1120 is due on the 1st day of the 5th month after the close of the fiscal year (e.g., June 1 for a fiscal year ending January 31).
Extension requirements
Form F-7004 grants a six-month extension of time to file (not to pay). To obtain a valid extension: 1. File F-7004 by the original Florida due date. 2. Pay at least the tentative tax due with the F-7004 (estimated total Florida tax liability minus credits and prior payments). Failure to pay 100% of the tentative tax with the extension renders the extension invalid, exposing the taxpayer to failure-to-file penalties from the original due date. This is a common trap — Florida is stricter on extension validity than the IRS. The extension period is six months from the original due date. For a calendar-year filer with an original due date of May 1, 2026, the extended due date is November 1, 2026.
E-filing mandate
Corporations with $20,000 or more in Florida corporate income tax liability in the prior state fiscal year (July 1 – June 30) MUST file F-1120 and pay electronically. Below that threshold, e-filing is voluntary but encouraged. E-filing is via: Modernized e-File (MeF) through approved software providers. Direct via FL DOR's online portal (limited).
Failure to file penalty
10% of the tax due per month or fraction thereof, up to 50%.
Failure to pay penalty
10% of the unpaid tax. Statutory floor of $10 even if the percentage is less.
Interest rate
Variable rate, adjusted semiannually by the FL DOR. Currently around 9% per annum (verify the current rate from TIP issued each January and July).
Fraud penalty
100% penalty.s. 220.803, F.S.
Negligence penalty
25% penalty.s. 220.803, F.S.
Estimated payment threshold
$2,500s. 220.222, F.S.
Installment due dates
| Installment | Due date | % of total | |---|---|---| | 1st | May 31 (last day of 5th month of tax year) | 25% | | 2nd | June 30 (last day of 6th month) | 25% | | 3rd | September 30 (last day of 9th month) | 25% | | 4th | January 31 of following year (last day of tax year + 1 month) | 25% |s. 220.34, F.S.
Fiscal-year substitution
For fiscal-year filers, substitute the corresponding months of the fiscal year.
Estimated payment form
Estimated payments are made with Form F-1120ES (or electronically). Each installment is generally 25% of the estimated full-year tax, though the annualized-income method is permitted for taxpayers with seasonal income.
Underpayment penalty and safe harbors
Underpayment of estimated tax is penalized under s. 220.34(2), F.S. The penalty is computed on Form F-2220. Safe harbors include: Pay 100% of prior year's actual Florida tax (only if prior year was a full 12 months and Florida tax was greater than zero). Pay 90% of current year's actual Florida tax through estimated payments. Annualized income installment method for irregular-income taxpayers. The penalty rate equals the statutory interest rate (currently ~9%).s. 220.34(2), F.S.
Capital Investment Tax Credit
For corporations making a "qualifying project" investment in Florida of at least $25 million in certain target industries (clean energy, biomedical, financial services, information technology, silicon technology, transportation equipment manufacturing). Up to a 100% offset of the Florida corporate income tax attributable to the project, over up to 20 years. Application to Enterprise Florida is required before the project begins. This is a high-bar credit aimed at large corporate relocations.s. 220.191, F.S.
R&D Tax Credit
A credit equal to 10% of qualified research expenses in Florida that exceed the taxpayer's average Florida QRE for the prior four years. The credit: Mirrors the federal IRC §41 R&D credit definition of qualified research. Requires the taxpayer to be in one of the target industries (manufacturing, life sciences, information technology, aviation/aerospace, homeland security/defense, cloud information technology, marine sciences, materials science, nanotechnology). Requires an allocation from the FL DOR — total annual credit is capped at $9 million statewide, allocated by application on a first-come basis each year. The application window opens March 20 of the year following the tax year. Unused credit carries forward 5 years.s. 220.196, F.S.; IRC §41
Voluntary Cleanup Tax Credit
A credit for voluntary cleanup of brownfield sites and dry-cleaning solvent contamination. 50% of cleanup costs, capped at $500,000 per site per year. Statewide annual cap of $5 million. Application to FL DEP required. Useful for real estate developers and industrial users.s. 220.184, F.S.
Tax Credit Scholarship Program
A dollar-for-dollar credit (up to 100% of Florida corporate income tax) for contributions to scholarship-funding organizations (SFOs) that fund private school scholarships for low-income students. The corporation makes a contribution to a state-approved SFO (Step Up For Students is by far the largest). The credit equals the contribution amount, up to the corporation's Florida tax liability. Application to FL DOR via the e-services portal is required before the contribution. Unused credit carries forward 5 years (10 years for excess contributions). The same contribution cannot be deducted as a charitable deduction federally if claimed as a Florida credit (Reg. §1.170A-1(h)(3)). This is the most-used Florida credit for small and mid-sized C-corps because it converts what would be Florida tax into a directed contribution at no net cost.s. 220.1875, F.S.; Reg. §1.170A-1(h)(3)
Other Florida credits
Community Contribution Tax Credit (s. 220.183) — 50% of contributions to approved community development projects, capped statewide. Hazardous Waste Facility Tax Credit (s. 220.1845). Renewable Energy Production Credit (s. 220.193) — closed to new applicants. Strong Families Tax Credit (s. 220.1876) — contributions to eligible charitable organizations serving families. Florida New Markets Tax Credit (s. 220.185). Experiential Learning Tax Credit (s. 220.198) — for businesses hosting student internships. Internship Tax Credit Program (s. 220.198). Child Care Tax Credit (s. 220.1873). All Florida credits require contemporaneous documentation. Most require pre-approval by the DOR or a partner agency. Refer to F-1120 Schedule V for the credit summary.s. 220.183, F.S.; s. 220.1845, F.S.; s. 220.193, F.S.; s. 220.1876, F.S.; s. 220.185, F.S.; s. 220.198, F.S.; s. 220.1873, F.S.
Credit ordering rule
Credits are applied in the order specified in s. 220.02(8), F.S. Generally, credits without carryforward are taken first, followed by carryforward credits. The Florida Tax Credit Scholarship credit has a 5-year carryforward and is taken after non-carryforward credits.s. 220.02(8), F.S.
No additional entity taxes
Florida does NOT impose: A general corporate franchise tax (separate from the income tax). A net worth tax. A privilege tax for the privilege of doing business as a corporation. A "minimum" corporate income tax (Florida's tax is purely income-based — if Florida apportioned income is below $50,000, no tax is due). A gross receipts tax on corporations. A capital stock tax. The Florida corporate income tax IS labeled as the "corporate income/franchise tax" in s. 220.11, F.S., but functionally it is an income tax. There is no separate franchise component.s. 220.11, F.S.
F-1120A eligibility criteria
Florida allows small corporations meeting all of the following to file Form F-1120A (short form): Florida net income < $45,000. Sales, property, and payroll factors are 100% Florida (no apportionment). No federal NOL carryforward. No federal alternative minimum tax. Not part of a controlled group. Not a homeowners' or condominium association. Not claiming any credits other than estimated payments. F-1120A is a one-page return. Eligibility is narrow but useful for small Florida-only C-corps.
s. 220.03, F.S.
Definitions (including federal IRC conformity date).s. 220.03, F.S.
Tax imposed; 5.5% rate
5.5%s. 220.11, F.S.
Tax Refund and Rate Reduction Mechanism
TRIM Act; historical 2018–2021.s. 220.1105, F.S.
Adjusted federal income (additions and subtractions); Florida NOL
Adjusted federal income (additions and subtractions); Florida NOL.s. 220.13, F.S.
Consolidated returns
Consolidated returns.s. 220.131, F.S.
$50,000 exemption
$50,000s. 220.14, F.S.
Three-factor apportionment with double-weighted sales; cost-of-performance sourcing for services
Three-factor apportionment with double-weighted sales; cost-of-performance sourcing for services.s. 220.15, F.S.
Special apportionment for transportation services
Special apportionment for transportation services.s. 220.151, F.S.
Petition for alternative apportionment
Petition for alternative apportionment.s. 220.152, F.S.
Allocation of nonbusiness income
Allocation of nonbusiness income.s. 220.16, F.S.
Community Contribution Tax Credit
Community Contribution Tax Credit.s. 220.183, F.S.
Voluntary Cleanup Tax Credit
Voluntary Cleanup Tax Credit.s. 220.184, F.S.
Hazardous Waste Facility Credit
Hazardous Waste Facility Credit.s. 220.1845, F.S.
New Markets Tax Credit
New Markets Tax Credit.s. 220.185, F.S.
Florida Tax Credit Scholarship Program
Florida Tax Credit Scholarship Program.s. 220.1875, F.S.
Strong Families Tax Credit
Strong Families Tax Credit.s. 220.1876, F.S.
Capital Investment Tax Credit
Capital Investment Tax Credit.s. 220.191, F.S.
Research and Development Tax Credit
Research and Development Tax Credit.s. 220.196, F.S.
Experiential Learning Tax Credit (Internship Tax Credit)
Experiential Learning Tax Credit (Internship Tax Credit).s. 220.198, F.S.
Returns; due dates
Returns; due dates.s. 220.222, F.S.
Declaration of estimated tax; quarterly payments
Declaration of estimated tax; quarterly payments.s. 220.34, F.S.
Bank and savings association franchise tax
Bank and savings association franchise tax.s. 220.63, F.S.
Penalties
Penalties.s. 220.803, F.S.
Adjusted federal income (F.A.C.)
Adjusted federal income.Rule 12C-1.013, F.A.C.
Apportionment; sales factor; cost-of-performance
Apportionment; sales factor; cost-of-performance.Rule 12C-1.0155, F.A.C.
Property factor (F.A.C.)
Property factor.Rule 12C-1.0151, F.A.C.
Payroll factor (F.A.C.)
Payroll factor.Rule 12C-1.0152, F.A.C.
Prohibition on personal income tax on natural persons
Prohibition on personal income tax on natural persons.Art. VII, s. 5, Fla. Const.
Corporate income tax authorization
Corporate income tax authorization.Art. VII, s. 6, Fla. Const.
Form F-1120
Florida Corporate Income/Franchise Tax Return.FL DOR Forms (2025)
Form F-1120A
short form.FL DOR Forms (2025)
Form F-1120ES
estimated tax voucher.FL DOR Forms (2025)
Form F-7004
extension.FL DOR Forms (2025)
Form F-2220
underpayment of estimated tax.FL DOR Forms (2025)
Form F-1065
partnership information return — corporate partners only.FL DOR Forms (2025)
TIP 22C01-02
rate restored to 5.5% for 2022.TIP 22C01-02
TIP 22C01-01
2021 rate retroactively reduced to 3.535%.TIP 22C01-01
TIP 21C01-01
2020 rate 3.535%.TIP 21C01-01
TIP 20C01-01 and TIP 19C01-04
2019 and 2018 rates 4.458%.TIP 20C01-01 and TIP 19C01-04
Net operating losses (Florida-mirrored post-2017)
Net operating losses (Florida-mirrored post-2017).IRC §172
Bonus depreciation (Florida decoupled)
Bonus depreciation (Florida decoupled).IRC §168(k)
Section 179 expensing (Florida partial decoupling)
Section 179 expensing (Florida partial decoupling).IRC §179
Ownership change NOL limit (Florida conforms)
Ownership change NOL limit (Florida conforms).IRC §382
GILTI (Florida partial subtraction)
GILTI (Florida partial subtraction).IRC §951A
Transition tax (Florida addback, historical)
Transition tax (Florida addback, historical).IRC §965
Built-in gains tax (S-corp)
Built-in gains tax (S-corp).IRC §1374
Excess net passive income tax (S-corp)
Excess net passive income tax (S-corp).IRC §1375
Federal R&D credit (referenced by FL §220.196)
Federal R&D credit (referenced by FL §220.196).IRC §41
Charitable contribution / state tax credit interaction
Charitable contribution / state tax credit interaction.IRC §170 / Treas. Reg. §1.170A-1(h)(3)
Safe harbor for state tax credit contributions
Safe harbor for state tax credit contributions.Notice 2019-12
Federal interstate commerce protection
Federal interstate commerce protection (tangible personal property only; does not protect SaaS or services).P.L. 86-272
us-tax-workflow-base
workflow architecture, required base.Companion skills
us-sole-prop-bookkeeping
Schedule C classification (federal); confirms whether SMLLC files Schedule C (and therefore no Florida F-1120).Companion skills
us-federal-return-assembly
federal 1040 / 1120 assembly.Companion skills
us-s-corp-election-decision
relevant for Florida sole proprietors considering S-corp election (federal-only analysis since FL has no SE tax).Companion skills
florida-sales-and-use-tax (separate skill)
Ch. 212, F.S. obligations for taxable sales.Companion skills
Rendered from the canonical facts model · facts last reviewed Jun 25, 2026. General reference only — confirm with a qualified professional before acting.
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