Side-by-side at $1,000,000 qualified income, 37% bracket
| Field | Georgia | South Carolina |
|---|---|---|
| Statute | O.C.G.A. § 48-7-23 (PTE election); HB 149 (2021) | S.C. Code § 12-6-545(G) (election for PTE entity-level 3% tax) |
| Election deadline | Annual irrevocable election made by checking the box on a timely-filed (including extensions) Form 700 (partnership) or Form 600S (S corp). Election must be made by the due date or extended due date of the entity return. | [PLACEHOLDER: state DOR cite] — pin election timing rules in SC1065/SC1120S instructions. |
| Rate | 5.39% flat | 3.00% flat |
| Owner credit | non-refundable | non-refundable |
| Composite interaction | stacks | stacks |
| §199A QBI reduction | Yes | Yes |
| Last verified | 2026-05-11 | 2026-05-11 |
Reference federal-arbitrage computation
Both scenarios assume $1,000,000 qualified net income, a 37% owner federal bracket, and no apportionment. Both reduce §199A QBI base proportionally; net benefit shown is the federal SALT-arbitrage less the rough QBI offset (~20% × bracket × entity tax).
Entity-level tax: $53,900. Net of QBI offset (~$3,989): $15,954.
Entity-level tax: $30,000. Net of QBI offset (~$2,220): $8,880.
Why owners with K-1 income across these two states care
Georgia and South Carolina interact in three ways that matter to a multi-state K-1 holder: (1) independent elections — each state's PTET is its own election with its own deadline and form, so a missed GA deadline does not affect SC; (2) aggregate federal deduction — the entity-level tax paid to BOTH states is deductible at the federal entity level under IRS Notice 2020-75, so the federal arbitrage compounds; (3) composite-return interaction may differ — see each state's row above.
Run the multi-state picker pre-filled with both jurisdictions: