Ezel / Tax Rulings / CT
CT Ruling 90-68 Sales and Use Taxes 1990-10-01

Were a common carrier's Connecticut courier charges for picking up and delivering packages subject to sales and use tax?

Short answer: No. The company was an authorized common carrier primarily picking up and delivering packages under 70 pounds between Connecticut offices and businesses, with additional interstate authority for Massachusetts and New York. DRS held the pickup and delivery services were not among the taxable services in Conn. Gen. Stat. § 12-407(2)(i).

Apply this to your situation

This page answers the general question as of 1990. Ezel answers yours, under current Connecticut tax law, with citations.

Currency note: this ruling is from 1990
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 Ruling of the Connecticut Department of Revenue Services (DRS), typically issued to a specific taxpayer in response to that taxpayer's request and based on the specific facts presented and the Connecticut tax law in effect when it was issued. DRS may later declare a Ruling obsolete or supersede it by a subsequent Ruling, Policy Statement, or Announcement, so a taxpayer with different facts should not assume it still applies. Taxpayer-identifying details are redacted. Connecticut imposes its 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

A Connecticut-authorized common carrier picked up and delivered packages, primarily under 70 pounds, between offices and businesses throughout the state. It also held authority for interstate deliveries involving Massachusetts and New York.

DRS held that the courier's pickup and delivery services were not subject to sales and use tax under the taxable-services list in Conn. Gen. Stat. § 12-407(2)(i).

What this means for you

The ruling addressed a regulated common carrier performing straightforward package transportation. Services that add storage, protective, logistics, or other functions may require separate analysis.

Common questions

Were intrastate courier deliveries taxable? No under the ruling.

Did the company's interstate authority change the answer? The ruling described that authority but gave one nontaxable answer for the pickup and delivery services.

Citations and references

  • Conn. Gen. Stat. § 12-407(2)(i).

Source

Original ruling text

Ruling 90-68, Courier Services

Ruling 90-68

Courier Services

ISSUE:

Whether the services rendered by Company X in picking up and delivering packages in its capacity as a common carrier are subject to sales and use tax.

FACTS:

X Company is engaged as a common carrier with authority from the State of Connecticut to pickup and deliver packages between all points in the State of Connecticut. They are primarily involved with the pickup and delivery of packages under 70 pounds between offices and businesses as a courier. X Company has obtained authority to make interstate deliveries between Connecticut, Massachusetts and New York.

In accordance with the requirements of State statute, X Company has filed a tariff with the Department of Transportation for the State of Connecticut concerning their fees for pickups and deliveries within State boundaries.

RULING:

The services rendered by X Company in picking up and delivery packages are not subject to sales and use tax under the provisions of Section 12-407(2)(i) of the Connecticut General Statute.

LEGAL DIVISION

October 1, 1990

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