Which Mississippi county does an out-of-state resident register a vehicle in if they keep it on land they own with a camper on it?

Plain-English summary

The Scott County Board of Supervisors asked the Mississippi Attorney General about a case where the county tax assessor denied a vehicle tag to an out-of-state resident who owns property in the county with a camper on it and keeps his car there, using it only in Mississippi. The AG's office confirmed the governing rule: since a 1992 amendment to Mississippi Code Annotated Section 27-19-57(1), what matters for vehicle registration and taxes is where the vehicle is domiciled, meaning where it normally comes to rest and is garaged for most of the year, not where its owner legally resides.

The opinion does not decide whether this particular vehicle is domiciled in Scott County; that is a factual determination for the tax assessor to make. But it lays out the test: for informational purposes, state administrative rules define "domiciled" as the county from which a vehicle leaves and to which it returns, where it comes to rest, and where it is garaged for the majority of the registration year. If the assessor finds the car meets that test, the owner has to get a Mississippi tag regardless of where they legally live.

What this means for you

County tax assessors and boards of supervisors

The opinion holds that Section 27-19-57(1) requires vehicle owners to register and pay privilege taxes in the county where the vehicle is domiciled, and that this is a factual question the assessor must decide using guidance like the state's administrative definition of "domiciled." The opinion also confirms the office does not make that factual call itself or interpret another agency's rules by official opinion.

Out-of-state property owners who keep a vehicle in Mississippi

The opinion holds that owning property in Mississippi while legally residing elsewhere does not exempt a vehicle from Mississippi registration if the vehicle is actually domiciled here, meaning it is kept, garaged, and normally comes to rest in the state for most of the year. Also note the opinion's point that it is possible for a vehicle to have a legal situs in another state but still owe Mississippi's privilege tax because of its usage here.

Attorneys advising clients on vehicle tax and registration disputes

The opinion confirms the domicile-of-the-vehicle test, not the residence-of-the-owner test, has governed since the 1992 amendment to Section 27-19-57(1), and that the tax collector may not issue a tag for a vehicle domiciled or garaged in another county.

Common questions

Q: Does living out of state exempt my vehicle from Mississippi registration?
A: Not necessarily. The opinion explains that a vehicle can have a legal situs elsewhere but still be subject to Mississippi privilege taxation because of how and where it is actually used.

Q: What factors determine where a vehicle is "domiciled" for tag purposes?
A: The opinion cites the state's administrative definition: the county, city, and taxing district from which the vehicle leaves and to which it returns, where it comes to rest, and where it is garaged, for the majority of the registration year.

Q: Can a county tax collector issue a tag for a vehicle domiciled somewhere else?
A: No. Section 27-19-57(1) states the tax collector "shall not issue a tag or decals to any vehicle domiciled or garaged in another county."

Q: Who decides whether a specific vehicle is domiciled in a given county?
A: That is a factual determination, according to the opinion, generally made by the county tax assessor rather than by the Attorney General's office.

Background and statutory framework

Before 1992, Mississippi law tied vehicle registration and taxation to where the owner resided. A 1992 amendment to Section 27-19-57(1) shifted the focus to where the vehicle itself is domiciled and used. The statute requires anyone paying the motor vehicle privilege tax to register their vehicle and pay taxes in the county where it is domiciled or from which it most frequently leaves and returns, and bars a county tax collector from issuing a tag to a vehicle domiciled or garaged in another county. The Mississippi State Tax Commission's administrative rules provide further guidance for making the domicile determination, though the Attorney General's office does not interpret another agency's own rules by official opinion.

Citations and references

Statutes:
- Miss. Code Ann. § 27-19-57(1), vehicle registration and privilege tax based on county of domicile

Prior AG opinions referenced: Gowan, Jr. (Mar. 23, 1994); Dulaney (Apr. 25, 2008); Brewer (May 18, 1995); Blaker II (June 14, 1996); Prisock (Oct. 9, 2015); Middleton (Jan. 26, 1988)

Source

• Index page: https://attorneygenerallynnfitch.com/divisions/opinions-and-policy/recent-opinions/
• Original PDF: https://attorneygenerallynnfitch.com/wp-content/uploads/2026/06/R.-Lee-Jr.-June-8-2026-Domicile-of-Vehicle-for-Determining-Whether-Owner-is-Required-to-Obtain-a-Mississippi-Tag.pdf

Original opinion text

June 8, 2026
Roy Noble Lee, Jr., Esq.
Attorney, Scott County Board of Supervisors
Post Office Box 370
Forest, Mississippi 39074
Re:

Domicile of Vehicle for Determining Whether Owner is Required to Obtain
a Mississippi Tag

Dear Mr. Lee:
The Office of the Attorney General has received your request for an official opinion.
Background
According to your request, the Scott County Board of Supervisors ("Board") has been approached
by an individual claiming he was improperly denied a tag for his automobile in Scott County by
the tax assessor's office. The individual is an out-of-state resident who owns property in Scott
County with a camper situated on it. The individual only uses the automobile in Mississippi and
keeps it on his property in Scott County.
Questions Presented
1. What are the determining factors to show that a vehicle is domiciled in a county?
2. Must the vehicle remain at the designated location at all reasonable times?
3. May a county issue a tag to a parcel of property that does not contain a residence other than a
recreational camper?
Brief Response
1. Whether a motor vehicle is domiciled or situated in this state is a determination of fact. MS
AG Op., Gowan, Jr. at 1 (Mar. 23, 1994). For informational purposes only, Mississippi
Administrative Code, Title 35, Part VII, Subpart 3, Chapter 01, Rule 102 states that
"'domiciled' means the county, city and taxing district from which a vehicle leaves and to
which a vehicle returns, where it comes to rest, where it is garaged, for the majority of the
registration year. It is the legal residence of a vehicle."
2. See response to question number 1.
3. The domicile or situs of the motor vehicle, not the residence of its owner, determines the county
in which the vehicle should be registered and taxes paid.
Applicable Law and Discussion
Purchasing a tag for a motor vehicle requires the payment of an ad valorem tax and a privilege tax.
MS AG Op., Dulaney at 1 (Apr. 25, 2008); MS AG Op., Gowan, Jr. at 1. The ad valorem tax
"is a property tax which generally attaches to any motor vehicle having a situs within Mississippi."
MS AG Op., Dulaney at 1; see also MS AG Op., Gowan, Jr. at 1. The privilege tax is a "tax for
use of the roads and bridges in this state." Id. "It is possible for a vehicle to have a legal situs in
another state but, because of its usage in Mississippi, be subject to privilege taxation." MS AG
Op., Gowan, Jr. at 1. In addition to the payment of these taxes, the motor vehicle must be
registered. MS AG Op., Dulaney at 1. "The determination of whether a vehicle is subject to the
taxes and registration, and in what county, are all questions of fact." Id.
Mississippi Code Annotated Section 27-19-57(1) provides:
All persons required to pay the privilege license prescribed by this article [Title 27,
Chapter 19, Article 1, "Motor Vehicle Privilege Taxes"] shall register their private
or commercial vehicle and pay such tax in the county in which such vehicles are
domiciled or the county from which such vehicles most frequently leave and return.
The tax collector of a county shall not issue a tag or decals to any vehicle domiciled
or garaged in another county.
Before 1992, this statute required motor vehicle owners to pay the required taxes and register their
vehicles in the county in which they resided. MS AG Op., Dulaney at 2. This statute was amended
in 1992 "to focus on where the vehicle is domiciled and used, as opposed to the residence of the
person." Id. Now Section 27-19-57(1) "requires an owner of a motor vehicle to register the vehicle
and pay privilege taxes in the county in which the vehicle is domiciled." MS AG Op., Brewer at
1 (May 18, 1995).
Whether a motor vehicle is domiciled or situated in this state is a determination of fact. MS AG
Op., Gowan, Jr. at 1; MS AG Op., Blaker II at * 1 (June 14, 1996). "The State Tax Commission,
through its rules and regulations is authorized by statute to provide additional guidance in making
this factual determination...." MS AG Op., Blaker II at 1. This office does not interpret the
rules and regulations of another state board or agency by official opinion. MS AG Op., Prisock at
3 (Oct. 9, 2015). However, for informational purposes, Mississippi Administrative Code, Title
35, Part VII, Subpart 3, Chapter 01, Rule 102 states that "'domiciled' means the county, city and
taxing district from which a vehicle leaves and to which a vehicle returns, where it comes to rest,
where it is garaged, for the majority of the registration year. It is the legal residence of a vehicle."
Further, this office has previously stated that situs of a motor vehicle for taxation is in the county
"where said motor vehicle is normally maintained." MS AG Op., Middleton at 2 (Jan. 26, 1988).
This office does not make factual determinations by official opinion. MS AG Op., Brewer at 1.
However, if the tax assessor finds that the automobile is domiciled in Scott County, "then the
owner would have to purchase a motor vehicle license tag in Mississippi." Id.
If this office may be of any further assistance to you, please do not hesitate to contact us.
Sincerely,
LYNN FITCH, ATTORNEY GENERAL
By:

/s/ Kristi D. Kennedy
Kristi D. Kennedy
Special Assistant Attorney General