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Accounting and state tax in Massachusetts

Massachusetts taxes corporations at 8% of apportioned income plus $2.60 per $1,000 of property or net worth, with a $456 minimum. From 2025 apportionment is by sales only.

Jurisdiction
Massachusetts
Reading time
2 min
Checked
October 12, 2026
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Key figures

Massachusetts accounting

2026, with sources

Income measure
8.0% of net incomeGeneral business and manufacturing corporations.
Non-income measure
$2.60 per $1,000Tangible property or net worth, added to the income measure.
Minimum excise
$456Never prorated for a short year.
Apportionment
Sales factor onlyTax years beginning on or after Jan 1, 2025.
Bonus depreciation
Decoupled§ 168(k) disallowed; § 168(n) not adopted for 2025.
IRC § 174A
Delayed one year2025: § 174 as of July 3, 2025; disallowance repealed from 2026.

Two measures and a minimum

Massachusetts calls its corporate tax an excise and computes it in two parts that are added together: an income measure of 8.0% of net income apportioned to Massachusetts, and a non-income measure of $2.60 per $1,000 of either taxable tangible property or net worth. The total is never less than $456, and the minimum is never prorated, even for a corporation that registered in December.

For most early-stage software companies the non-income measure is small and the $456 minimum is what they pay until they turn a profit. A company that raised a large round can have meaningful net worth, though, so the classification and the property measure are worth checking before assuming the minimum applies.

Sales-only apportionment and combined reporting

From tax years beginning on or after January 1, 2025, corporations apportion income to Massachusetts using the sales (receipts) factor only; property and payroll are used only in the rare years when the sales factor is inapplicable. For a Cambridge company with engineers in Kendall Square and customers nationwide, that is a real change: payroll in Massachusetts no longer pulls income into the state, while Massachusetts customers do.

Members of a unitary group under common control file a combined report on Form 355U. A startup with a Delaware parent and a Massachusetts operating subsidiary generally files as a combined group, and gets a seven-month extension instead of six.

Conformity and the provision

The corporate excise generally conforms to the Internal Revenue Code as currently in effect, with listed exceptions. The ones that matter to a startup: Massachusetts disallows federal bonus depreciation under § 168(k), did not adopt § 168(n) for qualified production property for 2025, and, under the June 2026 supplemental budget, disallowed the § 174A immediate deduction for 2025 only, requiring R&E to be deducted as § 174 stood on July 3, 2025. That disallowance is repealed for 2026.

Bonus depreciation is also disregarded in computing a Massachusetts net operating loss, which is carried forward under 830 CMR 63.30.2. In the provision, expect a Massachusetts-only depreciation difference that persists, and a one-year R&E difference for 2025 that unwinds.

Deadlines

  1. 15th day of the 4th month (Apr 15 for calendar years)Corporate excise returnForm 355 / 355U
  2. By the original due dateAutomatic extension (six months; seven for combined filers) if at least 50% of tax or $456 is paid
  3. QuarterlyEstimated payments if the excise is expected to exceed $1,000Form 355-ES

Common questions

Does Massachusetts tax more than income?

Yes, two measures added together: 8% of income apportioned to Massachusetts, plus $2.60 per $1,000 of either tangible property or net worth, depending on how the corporation is classified. A loss-making startup still pays the non-income measure, and never less than $456.

Can we expense R&D immediately in Massachusetts?

Not on the 2025 return. The June 2026 supplemental budget delayed conformity to § 174A: for 2025, corporations deduct R&E as § 174 allowed on July 3, 2025, and add back the immediate deduction. The disallowance is repealed for tax years beginning in 2026, so 2026 follows federal treatment, though the mechanics for catch-up deductions are still being set out by DOR.

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Sources

Checked against each agency’s own page on . Rates and thresholds change, usually on January 1.

General information for US companies, not tax, legal or accounting advice for yours. Rules and thresholds change; confirm the specifics with a CPA or the agency before you act on them.

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