Ezel / Tax Rulings / CT
CT Ruling 89-170 Sales and Use Taxes 1989-10-30

Were traffic-impact studies and related roadway or signal design services subject to Connecticut sales and use tax?

Short answer: No under this historical ruling. DRS excluded traffic-engineering services that evaluated proposed developments' roadway effects, recommended improvements for adverse traffic, and could include roadway-improvement and traffic-signal design.

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 addressing the described traffic-engineering services under the service rules then in effect. The published text cites no statute or broader legal test, so another taxpayer should not extend it beyond comparable traffic-impact studies, recommendations, roadway improvements, and signal design. 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 traffic engineer studied proposed developments for municipalities and private developers to determine effects on the surrounding roadway network. When the study found adverse traffic effects, the engineer recommended improvements and could design roadway changes and traffic signals.

DRS concluded that the described traffic-engineering services were not subject to sales and use tax.

What this means for you

The brief historical ruling covers the listed traffic-impact analysis, recommendations, and related design work and gives no broader legal test.

Common questions

Were traffic-impact studies taxable? No under the ruling.

Did the service include improvement recommendations? Yes.

Could it include roadway and signal design? Yes.

Citations and references

  • The published ruling text does not cite a specific statute or regulation.

Source

Original ruling text

Ruling 89-170, Engineering

You render traffic engineering services whereby you conduct traffic impact studies to developments being proposed for municipalities and private development companies. The traffic impact study involves providing advice concerning whether a proposed development will have an impact on the surrounding roadway network. When the impact on the traffic flow will be adverse, you make recommendations to improve the traffic that will be generated by the site. You may design roadway improvements, as well as traffic signals.

Based on the above set of facts, the traffic engineering services that you perform are not subject to sales and use tax.

LEGAL DIVISION

October 30, 1989

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