Okla. Stat. tit. 68, § 68-2366: Allocation of income and deductions

The Tax Commission may allocate gross income, gains, losses,

deductions, credits or allowances between two or more organizations,

trades or businesses (whether or not incorporated, or organized in

the United States or affiliated) owned or controlled directly or

indirectly by the same interests, if the Tax Commission reasonably

determines such allocation is necessary to prevent evasion of taxes

or to clearly reflect income of the organizations, trades or

businesses. Each such organization shall be deemed to be

transacting business in Oklahoma and subject to all the provisions

of this act. This section shall apply only with respect to related

organizations, trades or businesses which in the aggregate derive

income both within and outside the State of Oklahoma and then only

with respect to such income, deductions, credits or allowances

related thereto.