BobKamman
Level 15

All I know is what the Franchise Tax Board tells me.  

"Some key features of a partnership are:

https://www.ftb.ca.gov/file/business/types/partnerships.html

It doesn't make any difference if the business has no customers in California.  Where do they have offices, warehouses, factories, employees?  And even if those are in China, if  the business has chosen California as its residence, it has also chosen to pay California tax on its profits. 

"We have no customers in California" sounds like someone's feeble excuse for not wanting to pay taxes there.  It won't work.