Ezel / Tax Rulings / CT
CT Ruling 89-193 Sales and Use Taxes 1989-11-06

How did Connecticut source sales and use tax on multistate tool-sharpening services?

Short answer: The ruling sourced the service to the property owner's location. A Massachusetts tool owner did not owe tax for Connecticut sharpening, while Connecticut owners owed tax whether sharpening occurred in Connecticut or out of state, with use tax on the latter. DRS says AN 2000(8) partly obsoleted it.

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 reflecting the repair-service sourcing rules then in effect. DRS expressly marks the information 'not current' and says Announcement (AN) 2000(8) obsoleted it in part. Its owner-location treatment of Connecticut and Massachusetts tool-sharpening transactions should not be assumed current. 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)

Note -- partially obsolete historical guidance. DRS marks this information "not current" and states that Announcement (AN) 2000(8) obsoleted the ruling in part.

Plain-English summary

The ruling states that repair and maintenance services became taxable on July 1, 1989 and that taxability was based on the property owner's location.

A Massachusetts tool company did not owe Connecticut tax when a Connecticut firm sharpened its tools. Connecticut companies receiving tool-sharpening services owed tax. When a Connecticut company used an out-of-state sharpener, use tax applied.

What this means for you

The historical rule focused on the tool owner's location rather than where sharpening occurred. AN 2000(8) later obsoleted the guidance in part.

Common questions

Did a Massachusetts tool owner owe tax for sharpening in Connecticut? No under the ruling.

Did a Connecticut tool owner owe tax for sharpening in Connecticut? Yes.

What if a Connecticut owner used an out-of-state sharpener? Use tax applied.

Citations and references

  • Announcement (AN) 2000(8) -- identified by DRS as partly obsoleting this ruling.

Source

Original ruling text

Ruling 89-193, Repairs

This information is not current and is being provided for reference purposes only

Ruling 89-193

Repairs

This Ruling has been obsoleted in part by  AN 2000(8)

As of July 1, 1989, repair and maintenance services are subject to sales and use taxes. The taxes are based on the location of the owner of the property. Thus, a Massachusetts tool firm is not subject to tax on a Connecticut firm sharpening its tools.

However, all Connecticut companies receiving tool sharpening services are subject to sales and use tax. If a Connecticut company uses an out-of-state company to sharpen its tools, a use tax would apply to such service.

It is this Department's goal to protect those providing services in Connecticut from the situation described in your letter. We will vigorously enforce the tax laws of this state against Connecticut companies going outside the state for services.

TIMOTHY F. BANNON

COMMISSIONER

November 6, 1989

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