Ezel / Tax Rulings / CT
CT Ruling 89-29 Sales and Use Taxes 1989-07-17

Were services to paint business vehicles taxable, and could a vehicle lessor buy them for resale, under Connecticut Ruling 89-29?

Short answer: Painting business vehicles, including vehicles leased to a business, was taxable. A motor-vehicle leasing company could not buy the painting service for resale because the lessor consumed the service. The ruling is partly superseded and obsolete.

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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 1989 Connecticut Department of Revenue Services Ruling is not current. The official page says it was superseded in part by Ruling 90-60 and obsoleted by Announcement 2000(8), so it is provided only as historical reference and should not be used as current authority. It addressed business-vehicle painting and a motor-vehicle lessor's resale claim under the law then in effect. 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 current vehicle-service treatment.
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

Painting business vehicles was subject to sales and use taxes under this ruling, including painting vehicles that a motor-vehicle leasing company leased to a business.

The leasing company could not buy the painting service for resale because the Department treated the lessor as consuming the service.

The official archive says the ruling was superseded in part by Ruling 90-60 and obsoleted by Announcement 2000(8).

What this means for you

The historical ruling treated the painting as a taxable service to the vehicle owner or lessor, not as a service resold to the lessee. Its superseded and obsolete status means current resale and repair rules must be checked separately.

Common questions

Was painting a business vehicle taxable? Yes.

Did the same rule apply to vehicles leased to a business? Yes.

Could the leasing company purchase the painting for resale? No, because it consumed the service.

Citations and references

  • No statute or regulation was cited in the ruling text.

Source

Original ruling text

Ruling 89-29, Motor Vehicle Repairs

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

Ruling 89-29

Motor Vehicle Repairs

This Ruling has been superseded in part by   Ruling 90-60 ;  obsoleted by   AN 2000(8 )

Please be advised that the service of painting business vehicles, including vehicles leased to a business by a motor vehicle leasing company, is subject to sales and use taxes. Also, painting services cannot be purchased for resale by a motor vehicle leasing company, because these services are consumed by the leasing company.

LEGAL DIVISION

July 17, 1989

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