The denominator of the payroll factor is the total compensation paid everywhere during the tax period. Accordingly, compensation paid to employees whose services are performed entirely in a state where the taxpayer is immune from taxation, for example, by Public Law 86-272, are included in the denominator of the payroll factor.

[1/15/74, 9/15/88, 9/20/93, 1/15/97; 3.5.14.9 NMAC - Rn & A, 3 NMAC 5.14.9, 6/29/01]