A divided en banc panel of the Pennsylvania Commonwealth Court has ruled that global shippers should be taxed on the basis of revenues earned transporting goods through Pennsylvania, not just on the basis of miles covered in the state.

On a 4-3 vote, the court denied a request by the state Department of Revenue to adjust upward FedEx Ground Package System’s tax liability. The tax officials said that a three-judge panel had created a formula that was not prescribed by the statute by counting shipping rates charged in Pennsylvania, rather than the average rate charged by the company worldwide.

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