California Code, Public Utilities Code - PUC § 3440

(a) Golden State Energy shall be exempt from franchise and corporate income tax pursuant to Section 23701 of the Revenue and Taxation Code. Indebtedness issued by Golden State Energy and any transfer thereof shall be exempt from income taxation of every kind by the state.

(b) Property used exclusively by Golden State Energy in carrying out its purposes in Section 3402 shall not be exempt from taxation under subdivision (b) of Section 4 of, and Section 5 of, Article XIII of the California Constitution and Section 214 of the Revenue and Taxation Code.