Ezel / Tax Rulings / CT
CT Ruling 89-149 Sales and Use Taxes 1989-10-12

Was a service that arranged trademark licensing agreements subject to Connecticut sales and use tax?

Short answer: No. Based on the stated facts, the service provider arranged agreements between the trademark-owning corporation and manufacturers for use of the trademark, and DRS concluded that the arrangement service was not subject to sales and use tax.

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 applying the sales-and-use-tax treatment then in effect to the described service of arranging trademark licensing agreements. Its result is limited to the stated arrangement between the trademark-owning corporation and manufacturers and should not be extended to services involving different facts without further analysis. 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 your specific situation.
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

The client provided a service that arranged licensing agreements between a corporation that owned a trademark and manufacturers that would use it.

DRS concluded that this trademark-licensing arrangement service was not subject to sales and use tax.

What this means for you

The ruling provides a nontaxable result only for the specific arrangement service described in the request.

Common questions

Who were the parties to the licensing agreements? The trademark-owning corporation and manufacturers.

What did the service provider do? Arranged the licensing agreements.

Was that service taxable? No under the stated facts.

Source

Original ruling text

Ruling 89-149, Trademark/Licensing Agreement

Ruling 89-149

Trademark/Licensing Agreement

According to the information presented in your letter, your client renders a service whereby he arranges licensing agreements for use of a trademark owned by a corporation. The licensing agreements for use of the trademark are between the corporation that owns the trademark and manufacturers.

Based on the above set of facts, the service your client performs that involves arranging licensing agreements for use of a trademark is not subject to sales and use tax.

LEGAL DIVISION

October 12, 1989

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