Ezel / Tax Rulings / CT
CT Ruling 89-42 Sales and Use Taxes 1989-08-14

How did Connecticut Ruling 89-42 tax systems-design training provided to individuals and businesses?

Short answer: Training provided to individuals was not taxable if it was not connected with a sale of tangible personal property. The same systems-design training provided to businesses was subject to sales or use tax.

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 applying the law then in effect to educational systems-design training provided to individuals and businesses. Later statutory or administrative changes may produce a different result, and another training provider should not assume this historical ruling controls current services. 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 training-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

Educational training in systems design provided to individuals was not subject to sales or use tax if it was not performed in connection with a sale of tangible personal property.

The same type of training provided to businesses was subject to sales or use tax under the cited regulation.

What this means for you

The historical ruling made the customer's status important and added a separate condition for individual training: it could not be connected with a tangible-property sale. The ruling did not describe what materials, if any, accompanied the training.

Common questions

Was training for individuals taxable? No, if it was not connected with a sale of tangible personal property.

Was training for businesses taxable? Yes.

What subject did the training cover? Systems design.

Citations and references

  • Conn. Agencies Regs. § 12-426-27, as cited in the ruling.

Source

Original ruling text

Ruling 89-42, Training

Ruling 89-42

Training

Your inquiry relates to the taxability of educational training services in systems design.

Educational training services in systems design that are rendered to individuals are not subject to sales or use tax providing they are not performed in connection with the sale of tangible personal property.

Educational training services in systems design that are rendered to businesses are subject to sales or use tax pursuant to section 12-426-27 of the Regulations of Connecticut State Agencies.

TIMOTHY F. BANNON
COMMISSIONER

August 14, 1989

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