What were South Carolina's 2025 job-credit county tiers, tax-moratorium counties, and reduced-investment FILOT county?

Plain-English summary

This letter provides South Carolina's county-based economic-development classifications for 2025. It covers job tax credit tiers, tax-moratorium counties, and reduced minimum investment for fee in lieu of property taxes (FILOT).

The job-credit tiers were:

• Tier IV: Abbeville, Allendale, Bamberg, Barnwell, Cherokee, Dillon, Lee, Marion, Marlboro, Orangeburg, Union, Williamsburg.
• Tier III: Chester, Chesterfield, Clarendon, Colleton, Darlington, Fairfield, Greenwood, Hampton, Horry, Laurens, McCormick, Sumter.
• Tier II: Anderson, Calhoun, Edgefield, Florence, Georgetown, Jasper, Kershaw, Lancaster, Newberry, Pickens, Saluda.
• Tier I: Aiken, Beaufort, Berkeley, Charleston, Dorchester, Greenville, Lexington, Oconee, Richland, Spartanburg, York.

These tiers applied to new full-time jobs created in tax years beginning in 2025 where the credit was first earned on or after January 1, 2025, and to increases in new full-time jobs during 2025.

For the tax moratorium, Chesterfield, Marlboro, and Union Counties qualified. The statute can grant a 10-year moratorium, or 15 years in certain cases, on corporate income or insurance premium taxes for a qualifying taxpayer.

For FILOT, Marlboro County qualified for the reduced $1 million minimum investment under the Little Fee, Simplified Fee, and Big Fee programs. The ordinary minimums identified by the letter were $2.5 million for the Little and Simplified Fees and $45 million for the Big Fee.

Common questions

Q: Which counties qualified for the 2025 tax moratorium? A: Chesterfield, Marlboro, and Union.

Q: Which county qualified for the $1 million FILOT minimum? A: Marlboro County.

Q: How were the job-credit tiers determined?
A: By ranking all 46 counties with equal weight for unemployment rate and per capita income.

Citations and references

• S.C. Code Ann. §§ 12-6-3360 and 12-6-3367
• S.C. Code Ann. § 12-44-30(14)
• S.C. Code Ann. § 4-12-30(B)(3)
• S.C. Code Ann. § 4-29-67
• S.C. Code Ann. §§ 12-4-320 and 1-23-10(4)
• SC Revenue Procedure #09-3
• SC Revenue Ruling #19-11, Question 3

Source

• Landing page: https://dor.sc.gov/advisory-opinion-search
• Original PDF: https://dor.sc.gov/sites/dor/files/policies/IL24-21.pdf

Original ruling text

STATE OF SOUTH CAROLINA

DEPARTMENT OF REVENUE
300A Outlet Pointe Blvd., Columbia, South Carolina 29210
P.O. Box 125, Columbia, South Carolina 29214-0575

SC INFORMATION LETTER #24-21
SUBJECT:

Job Tax Credit - County Rankings for 2025
Fee in Lieu of Property Taxes – Reduced Investment Counties Tax Moratorium – Qualifying Counties

DATE:

December 18, 2024

REFERENCE:

S. C. Code Ann. Section 12-6-3360
S. C. Code Ann. Section 12-6-3367
S. C. Code Ann. Section 12-44-30
S. C. Code Ann. Section 4-12-30
S. C. Code Ann. Section 4-29-67

AUTHORITY:

S.C. Code Ann. Section 12-4-320
S.C. Code Ann. Section 1-23-10(4)
SC Revenue Procedure #09-3

SCOPE:

An Information Letter is a written statement issued to the public to announce general information useful in complying with the laws administered by the Department. An Information Letter has no precedential value.

INTRODUCTION
The job tax credit, the corporate tax moratorium, and the reduction in the minimum required fee in lieu of property tax investment are dependent, in part, on per capita income and unemployment rate data received from the South Carolina Department of Employment and Workforce and the United States Department of Commerce. The purpose of this information letter is to provide the county rankings for purposes of the job tax credit, counties qualifying for the corporate tax moratorium, and counties qualifying for the reduced fee in lieu of property tax. JOB TAX CREDIT – County Rankings South Carolina’s 46 counties are ranked and designated annually for job tax credit purposes with equal weight given to unemployment rate and per capita income as provided in South Carolina Code Section 12-6-3360(B). The final ranking of counties for (1) new full-time jobs created in 1

tax years that begin in 2025, where the job tax credit was first earned on or after January 1, 2025, and (2) increases in new full-time jobs in 2025 are listed below. 1 TIER IV Abbeville Allendale Bamberg Barnwell Cherokee Dillon Lee Marion Marlboro Orangeburg Union Williamsburg

TIER III

TIER II

Chester
Chesterfield
Clarendon
Colleton
Darlington
Fairfield
Greenwood
Hampton
Horry
Laurens
McCormick
Sumter

Anderson
Calhoun
Edgefield
Florence
Georgetown
Jasper
Kershaw
Lancaster
Newberry
Pickens
Saluda

TIER I
Aiken
Beaufort
Berkeley
Charleston
Dorchester
Greenville
Lexington
Oconee
Richland
Spartanburg
York

TAX MORATORIUM – Qualifying Counties
South Carolina Code Section 12-6-3367, in part, grants a 10-year moratorium (15 years in certain cases) on corporate income taxes or insurance premium taxes for qualifying taxpayers in a county with an average annual unemployment rate of at least twice the state average during each of the last two completed calendar years, based on the most recent unemployment rates available, or in a county with one of the three lowest per capita incomes based on the average of the three most recent years of available average per capita income data. The moratorium begins the first full taxable year after the taxpayer qualifies in a county designated as a moratorium county. For 2025, the following counties have been designated moratorium counties under South Carolina Code Section 12-6-3367. Chesterfield Marlboro Union FEE IN LIEU OF PROPERTY TAXES - Reduced Investment Counties The minimum required investment necessary to qualify for the fee in lieu of property taxes is $2.5 million for the “Little Fee” and “Simplified Fee,” and $45 million for the “Big Fee.” See South Carolina Code Sections 4-12-30(B)(3), 12-44-30(14), and 4-29-67, respectively. This investment amount, however, is reduced to $1 million for a company investing in a county with an average annual unemployment rate of at least twice the state average during each of the last 24 months, based on data available on November 1. For 2025, Marlboro County qualifies for the $1 million minimum investment under the “Little Fee,” “Simplified Fee,” and “Big Fee.” 1

For further information, see SC Revenue Ruling #19-11, Question 3 and the examples provided.

2