Florida tax credits you can transfer or buy: brownfield, railroad and the rest

By the Tax Field Guide editorial team. Published 2026-10-30. Facts checked 2026-10-30. Related strategies: Purchased Energy Credits, Research and Development Credits, Accelerated Depreciation.

Education only; not tax, legal or investment advice. Tax rules change, and how they apply depends on your facts. No outcome is guaranteed.

Florida has no personal income tax, but it does tax corporations: the corporate income tax rate is 5.5% of Florida net income, subject to the adjustments in section 220.1105.¹ That is why most Florida tax credits are written against the corporate income tax, and why the question "can this credit be sold?" comes up mainly for corporate buyers. The answer depends on the statute behind each credit. Most Florida credits cannot be sold at all. A few can be transferred under narrow rules. This guide sorts them using the current Florida Statutes. For every Florida credit we track, with amounts and sources, see the Florida state page. For transferable credits in all states, see transferable state tax credits.

Credits the statutes allow to be transferred

Contaminated site rehabilitation (voluntary cleanup) tax credit

The voluntary cleanup tax credit (VCTC) pays 50% of the costs of voluntary cleanup that is integral to rehabilitating an eligible site, such as a brownfield or a drycleaning-solvent contaminated site, with a limit of $500,000 per site per year. Extra 25% credits, each also capped at $500,000, apply in some cases, such as completing the cleanup or building affordable housing on the site.² The statewide limit is $35 million each fiscal year.³

On transfer, section 220.1845 says the credit may pass to the surviving or acquiring entity after a merger or acquisition. The entity may also transfer any unused credit, in whole or in units of at least 25% of the remaining credit. A transferred credit may not be transferred again, and each transferee has 5 years after the transfer to use it.³ The credit does not produce a refund: section 376.30781 says credits may not result in refunds when they exceed the tax owed.²

Credit for qualified railroad reconstruction or replacement expenditures

For taxable years beginning on or after January 1, 2023, Class II and Class III railroads can claim a credit equal to 50% of qualified track reconstruction or replacement spending in Florida. The credit is capped at $3,500 times the miles of track the railroad owns or leases in the state, and the application is due by May 1 of the following year.⁴

Unused credit carries forward 5 years or can be transferred, in whole or in part, by written agreement. The buyer must be a Florida corporate taxpayer that ships property over the railroad's facilities or supplies railroad-related property or services, or another railroad. The Department of Revenue must be notified. It sends a letter acknowledging the transfer, and the buyer attaches that letter to its return when it claims the credit.⁴

Capital investment tax credit (solar manufacturing exception only)

The capital investment tax credit for large projects in high-impact sectors generally cannot be carried forward or carried back. Only a project that includes a new solar panel manufacturing facility, creating at least 400 jobs with an average salary of at least $50,000, may assign or transfer the credit. The transferee must use it in the year it is received.⁵

Rural Community Investment Program credit

This newer program gives investors in an approved rural fund a credit equal to 25% of their investor contribution. The credit is claimed 20% a year in the tax years containing the first through fifth credit certification dates. The statute says the credit "may not be refunded, sold on the open market, or transferred," except to affiliates of the rural fund. The yearly cap is $7 million beginning in fiscal year 2025-26. No new applications are accepted after December 1, 2029, and the section expires December 31, 2040.⁶

Credits that stay with the taxpayer or its affiliated group

The contribution credits (Strong Families, the Florida Tax Credit Scholarship Program, Live Local, New Worlds Reading, Home Away From Home and the child care tax credits) share one rule. A taxpayer may not convey, transfer or assign the credit unless all of its assets are transferred in the same transaction. The one exception is a transfer between members of an affiliated group of corporations, with Department of Revenue approval.⁷ These credits are covered in Florida contribution tax credits.

The R&D credit, the community contribution credit, the rural and urban job credits, and the Individuals with Unique Abilities credit have no sale or transfer provision in their statutes. Unused amounts carry forward for the period the statute sets, which is 5 years for each of these.⁸

Two programs that are no longer open

Entertainment industry tax credit. Section 288.1254 was repealed July 1, 2016, and no new credits are being awarded. Credits certified under that program could be transferred once.⁹ The Department of Revenue's incentives page still lists the credit, which reflects old carryforwards, not new awards.
New markets tax credit. Florida's program expired December 31, 2022. Section 220.02(8) now refers to it as "former s. 288.9916".¹⁰

What a buyer should check

The statute section and the certificate or approval letter for the credit, and whether this credit type can be transferred at all.
Whether the seller has already transferred the credit. A VCTC that was transferred once cannot be transferred again.
How many carryforward years are left. The VCTC transferee has 5 years from the transfer, and a capital investment credit must be used in the year it is received.
That the Department of Revenue was notified, or that it acknowledged the transfer, where the statute requires it.
That the credit is one your company can use. These credits offset Florida corporate income tax, not federal tax.

Federal clean energy credits under section 6418 follow a different set of rules. See buying transferable solar tax credits and questions to ask a tax credit broker.

Florida firms listed here

Firms whose own sites describe related Florida work (listing is not an endorsement):

Carroll and Company, Tallahassee: VCTC application services and the CPA certification for VCTC filings.
The Goldstein Environmental Law Firm, Coral Gables: brownfield redevelopment and VCTC applications.
Kaufman Rossin, Miami: R&D credits and cost segregation.
Pivot CPAs, Ponte Vedra Beach: R&D credit studies and cost segregation.

Browse every listed firm on the advisor directory.

Common questions

Can you buy Florida tax credits?

Only some of them. The voluntary cleanup (brownfield) credit and the railroad reconstruction credit can be transferred under rules in the Florida Statutes. A capital investment tax credit can be transferred only for a qualifying solar panel manufacturing project. Most other Florida credits can move only to members of the same affiliated group, or not at all.

Can a Florida voluntary cleanup tax credit be transferred more than once?

No. Section 220.1845 allows an unused credit to be transferred in whole or in units of at least 25%, but a transferred credit may not be transferred again. Each transferee has 5 years to use it.

Is the Florida film tax credit still available?

No. The entertainment industry tax credit statute, section 288.1254, was repealed July 1, 2016, and no new credits are being awarded.

Are Florida corporate tax credits refundable?

The credits covered here are not refundable. The voluntary cleanup credit statute expressly bars refunds, and the others carry unused credit forward instead. The rural job tax credit program also has a separate, limited refund of sales tax paid on electricity.

Education only; not tax, legal or investment advice. Talk to a qualified professional before acting.

Sources

Florida Statutes §220.11 (2026), https://www.flsenate.gov/Laws/Statutes/2026/220.11
Florida Statutes §376.30781 (2026), https://www.flsenate.gov/Laws/Statutes/2026/376.30781
Florida Statutes §220.1845 (2026), https://www.flsenate.gov/Laws/Statutes/2026/220.1845
Florida Statutes §220.1915 (2026), https://www.flsenate.gov/Laws/Statutes/2026/220.1915
Florida Statutes §220.191 (2026), https://www.flsenate.gov/Laws/Statutes/2026/220.191
Florida Statutes §288.062 (2026), https://www.flsenate.gov/Laws/Statutes/2026/288.062
Florida Statutes §402.62(5) (2026), https://www.flsenate.gov/Laws/Statutes/2026/402.62
Florida Statutes §220.196, §220.183, §220.1895 and §220.1992 (2026), https://www.flsenate.gov/Laws/Statutes/2026/220.196
Florida Statutes §288.1254 (2015), https://www.flsenate.gov/Laws/Statutes/2015/288.1254
Florida Statutes §220.02 (2026), https://www.flsenate.gov/Laws/Statutes/2026/220.02

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