Ezel / Tax Rulings / CT
CT Ruling 89-169 Sales and Use Taxes 1989-10-30

When did fuel used to heat an industrial manufacturing plant qualify for Connecticut's sales-tax exemption?

Short answer: It was exempt under this historical ruling when at least 75% of the building, location, or premises was used directly in the manufacturing production process. DRS tied the heating-fuel exemption to Conn. Gen. Stat. § 12-412(16).

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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 manufacturing heating-fuel exemption then in effect. Its result depended on at least 75% of the building, location, or premises being used directly in manufacturing production; another taxpayer should not assume that historical threshold or exemption applies unchanged today. 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

Fuel used to heat an industrial manufacturing plant was exempt when at least 75% of the building, location, or premises was used directly in the manufacturing production process.

DRS tied that heating-fuel exemption to Conn. Gen. Stat. § 12-412(16), as amended in 1989.

What this means for you

The historical rule used a facility-level 75% manufacturing-production threshold.

Common questions

What fuel use qualified? Heating an industrial manufacturing plant.

What percentage threshold applied? At least 75% of the building, location, or premises had to be used directly in manufacturing production.

Citations and references

  • Conn. Gen. Stat. § 12-412(16), as cited in the ruling.
  • Public Act No. 89-251, as cited in the ruling.

Source

Original ruling text

Ruling 89-169, Utility Exemption - Manufacturing

The sale of fuel used for heating an industrial manufacturing plant is exempt from sales and use tax provided 75% or more of the building, location or premises is utilized directly in the manufacturing production process.

Therefore, section 12-412(16) of the Connecticut General Statutes, as amended by Public Act No. 89-251 provides a heating fuel exemption to manufacturers for heating an industrial manufacturing plant where 75% or more of the building or location is used for manufacturing production purposes.

LEGAL DIVISION

October 30, 1989

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