Ezel / Tax Rulings / CT
CT Ruling 89-103 Sales and Use Taxes 1989-09-26

How did Connecticut Ruling 89-103 tax graphic design for media advertising and for incorporation into printed materials?

Short answer: Graphic-design receipts were taxable when supplied to advertising agencies for media advertising and when incorporated into brochures and other tangible items. Agency fees for media advertising were not taxable. Ruling 95-7 later modified and partly superseded this ruling.

Apply this to your situation

This page answers the general question as of 1989. Ezel answers yours, under current Connecticut tax law, with citations.

Currency note: this ruling is from 1989
Subsequent statutory amendments, regulation changes, court decisions, or later rulings may have changed the analysis. Treat this page as historical context, not current tax advice. Verify current law before relying on any specific rule, rate, or position mentioned here.
Disclaimer: This is an official 1989 Connecticut Department of Revenue Services Ruling, but its page expressly says Ruling 95-7 later modified and superseded it in part. It is presented as historical reference, not as a complete statement of current graphic-design or advertising tax law. Connecticut imposes sales and use tax solely at the state level: there are no local or municipal sales taxes. This summary is informational only and is not legal or tax advice. Consult a licensed Connecticut tax professional about current treatment.
About this page: The plain-English summary, reader guidance, and Q&A below were written by Ezel based on the official state tax ruling. The original ruling (linked on this page as a PDF) is the authoritative source for any reliance.
View original ruling (PDF)

Plain-English summary

Total receipts for graphic-design work supplied to advertising agencies for media advertising were taxable. The advertising agencies' own fees for media advertising were not taxable under the cited provision.

The total sales price for graphic design provided for incorporation into tangible items was taxable. The ruling listed brochures, direct-mail pieces, forms, catalogs, annual reports, posters, newsletters, and sales materials as examples, and separately said sales of tangible personal property were taxable.

The official page says Ruling 95-7 later modified and superseded this ruling in part.

What this means for you

The historical ruling distinguished an agency's nontaxable media-advertising fee from the taxable graphic-design work it purchased. It also taxed design incorporated into tangible products. Because a later ruling changed it, current transactions require current guidance.

Common questions

Was graphic design for an advertising agency's media advertising taxable? Yes.

Was the agency's own media-advertising fee taxable? No under the ruling.

Was design incorporated into brochures or catalogs taxable? Yes, on the total sales price.

Did a later ruling change this result? The official page says Ruling 95-7 modified and superseded it in part.

Citations and references

  • Conn. Gen. Stat. § 12-407(2)(i)(W), as amended by Public Act No. 89-251, as cited in the ruling.
  • Ruling 95-7, identified by the official page as modifying and partly superseding this ruling.

Source

Original ruling text

Ruling 89-103, Graphic Design

This Ruling has been modified and superseded in part by Ruling 95-7

The total gross receipts for graphic design work rendered to advertising agencies for media advertising are subject to the sales and use tax. Advertising agencies' fees for media advertising are not taxable pursuant to section 12-407(2)(i)(W) of the Connecticut General Statutes, as amended by Public Act No. 89-251.

The total sales price for graphic design work provided to your clients for incorporation in an item of tangible personal property, such as brochures, direct mail pieces, forms, catalogs, annual reports, posters, newsletters, sales material, etc., are taxable. The sales of tangible personal property are subject to the sales and use tax.

LEGAL DIVISION

September 26, 1989

Get today's answer for your situation

You just read a 1989 ruling on this question. Ezel checks current Connecticut tax law and answers your specific situation, with citations.

Opens in Ezel Pro. Every answer cites the authority it relies on.