Ezel / Tax Rulings / CT
CT Ruling 89-259 Sales and Use Taxes 1989-12-07

Were total receipts for media-advertising services, including placement fees and development charges, subject to sales and use tax?

Short answer: No under this historical ruling. Total receipts for advertising services related to television, radio, newspaper, or periodical advertising were not taxable, including placement fees and development charges.

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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 media-advertising rules then in effect. Its result was limited to advertising related to television, radio, newspapers, or periodicals and included placement fees and development charges; the ruling does not address nonmedia advertising or state that it remains 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)

Plain-English summary

DRS ruled that the total gross receipts for services related to media advertising were not subject to sales and use tax under the historical provision. The nontaxable receipts included both placement fees and development charges.

For this ruling, media advertising meant advertising through television, radio, newspapers, or periodicals.

What this means for you

The historical exclusion covered the full charge for advertising tied to the four listed media channels. The short ruling does not address other advertising formats or mixed-media campaigns.

Common questions

Were placement fees taxable? No when related to the described media advertising.

Were development charges taxable? No under the same facts.

Which media did DRS identify? Television, radio, newspapers, and periodicals.

Citations and references

  • Conn. Gen. Stat. § 12-407(2)(i)(W), as amended by 1989 Conn. Pub. Acts 251.

Source

Original ruling text

Ruling 89-259, Advertising

The total gross receipts for advertising services related to media advertising, inclusive of placement fees and development charges, are not subject to sales and use tax pursuant to section 12-407(2)(i)(W) of the Connecticut General Statutes, as amended by Public Act No. 89-251.

Television, radio, newspapers or periodicals are considered to be media advertising.

LEGAL DIVISION

December 7, 1989

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