Ezel / Tax Rulings / CT
CT Ruling 97-4 Sales and Use Taxes 1997-08-26

Do heavy trailers used only for on-site storage still qualify for Connecticut's commercial-truck sales-and-use-tax exemption if they weigh over 26,000 pounds?

Short answer: Yes, they qualify. Trailers with a gross vehicle weight rating over 26,000 pounds can be bought or leased exempt under Connecticut's commercial-truck exemption (Conn. Gen. Stat. § 12-412(70)) even when the customer parks them and uses them only to store goods -- as long as the trailers stay 'suitable for use on the road' to convey property (for example, the wheels aren't removed). Trailers count as 'vehicles' and 'trailers' under the motor-vehicle definitions in § 14-1, and the exemption covers 'commercial trucks ... semitrailers, and vehicles used in combination therewith.' Actual storage use doesn't disqualify them.

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This page answers the general question as of 1997. Ezel answers yours, under current Connecticut tax law, with citations.

Currency note: this ruling is from 1997
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.
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Plain-English summary

Connecticut exempts heavy commercial vehicles from sales and use tax. Conn. Gen. Stat. § 12-412(70) covers sales, rentals, and leases of "commercial trucks, truck tractors, tractors and semitrailers, and vehicles used in combination therewith" that either have a gross vehicle weight rating (GVWR) over 26,000 pounds or are used actively and exclusively to carry interstate freight.

The company here leases empty trailers that customers park on their premises and use to store perishable goods — not to haul freight. Most of the trailers are over 26,000 pounds GVWR. Because the trailers are used for storage rather than interstate carriage, the interstate-freight branch of the exemption is irrelevant, so the question was whether the over-26,000-pound branch reaches trailers that are actually used just to store things.

DRS said yes — they qualify. Two definitions do the work. A "trailer" is "any rubber-tired vehicle without motive power drawn or propelled by a motor vehicle" (§ 14-1(a)(83)), and a "vehicle" is "any device suitable for the conveyance, drawing or other transportation of persons or property" (§ 14-1(a)(90)) — whether or not it's registered or actually used to convey property, as long as it remains "suitable" for that. So trailers fall within the exemption's phrase "vehicles used in combination therewith," and a heavy trailer bought separately from a tractor still qualifies. DRS analogized to Ruling No. 95-8, where a truck chassis was exempt at purchase because it was "suitable" for having freight-hauling apparatus mounted on it, even if later used differently.

The key condition is road-suitability: a storage trailer over 26,000 pounds qualifies "as long as [it] remain[s] suitable for use on the road to convey property" — DRS's example is that the wheels aren't removed. So parking a heavy trailer and filling it with inventory doesn't defeat the exemption; permanently disabling it for road use (e.g., removing the wheels) would.

What this means for you

Trailer leasing companies and lessees

If you buy or lease a trailer with a GVWR over 26,000 pounds, the § 12-412(70) exemption can apply even if the trailer is used purely for storage — provided it stays road-suitable. Actual use to haul freight isn't required; the statute keys off the vehicle's suitability, not its day-to-day job. Document the trailer's GVWR and its road-ready condition to support the exemption.

Watch the road-suitability line

The exemption depends on the trailer remaining suitable for use on the road to convey property. DRS's marker is concrete: don't remove the wheels. A trailer that's been permanently converted so it can no longer be towed and used on the road risks losing the exemption. Keep the unit tow-ready.

Weight threshold and the interstate alternative

Only trailers over 26,000 pounds GVWR qualify under this branch. There's a separate branch of § 12-412(70) for vehicles used actively and exclusively for interstate freight — not relevant to pure on-premises storage, but available for genuine interstate carriage regardless of weight.

Common questions

Q: Can a trailer used only for storage be exempt?
A: Yes. Under § 12-412(70), a trailer with a GVWR over 26,000 pounds can be bought or leased exempt even if it's parked and used only to store goods — so long as it stays suitable for use on the road to convey property.

Q: Why does a "storage" trailer count under a "commercial truck" exemption?
A: Because a trailer is a "vehicle" and a "trailer" under Conn. Gen. Stat. § 14-1, and it fits the exemption's category "vehicles used in combination therewith." The statute looks to whether the device is suitable for conveying property, not whether it's currently doing so.

Q: What would disqualify the trailer?
A: Losing road-suitability. DRS's example is removing the wheels. If the trailer can no longer be towed and used on the road to convey property, it falls outside the exemption.

Q: Does the trailer have to be registered or actually haul freight?
A: No. The "vehicle" definition applies whether or not the trailer is registered or actually used to convey property, as long as it remains suitable for that use. DRS drew the same conclusion for a truck chassis in Ruling No. 95-8.

Citations and references

Statutes:

  • Conn. Gen. Stat. § 12-412(70) (sales/use tax exemption for commercial trucks, truck tractors, tractors and semitrailers, and vehicles used in combination therewith, over 26,000 lbs GVWR or used exclusively for interstate freight)
  • Conn. Gen. Stat. § 14-1(a)(90) (definition of "vehicle": any device suitable for conveyance/transportation of persons or property)
  • Conn. Gen. Stat. § 14-1(a)(83) (definition of "trailer": a rubber-tired vehicle without motive power drawn or propelled by a motor vehicle)

Related ruling:

  • Ruling No. 95-8 (a truck chassis was exempt at purchase because it was "suitable" for freight-hauling apparatus, even if later used differently)

Source

Original ruling text

Ruling 97-4, Sales and Use Taxes / Commercial Truck Exemption / Storage Trailers

Ruling 97-4

Sales and Use Taxes

Commercial Truck Exemption

Storage Trailers

FACTS:

A company (the "Company") leases empty trailers to its customers, which park such trailers on their premises and use them to store perishable items. Most of the trailers rented by the Company have a gross vehicle weight rating of over 26,000 pounds.

ISSUES:

Whether trailers with a gross vehicle weight rating in excess of 26,000 pounds which are parked and used for storage may be purchased or leased under the exemption in Conn. Gen. Stat. 12-412(70) for commercial trucks, truck tractors, tractors and semitrailers, and vehicles used in combination therewith.

DISCUSSION:

Conn. Gen. Stat. 12-412(70) exempts sales, rentals and leases of commercial trucks, truck tractors, tractors and semitrailers, and vehicles used in combination therewith, which have a gross vehicle weight rating in excess of 26,000 pounds or are operated actively and exclusively for the carriage of interstate freight. Since the trailers leased by the Company are used by its customers for storage (and not for the carriage of interstate freight), the portion of the exemption relating to trailers used in interstate commerce is not pertinent, and only those trailers leased by the Company to its customers which have a gross vehicle weight rating in excess 26,000 pounds may qualify for exemption.

Although semitrailers are listed in connection with tractors in the exemption, trailers are also "vehicles" under Conn. Gen. Stat. 14-1(a)(90) ("any device suitable for the conveyance, drawing or other transportation of persons or property, whether operated on wheels, runners, a cushion of air or by any other means . . . "), even if they are not registered or actually used to convey property, because they are "suitable" for the conveyance of property. (See, for example, Ruling No. 95-8 , in which the Department ruled that a truck chassis was exempt at the time of its purchase, as long as it was "suitable" for having freight hauling apparatuses mounted on it, even if it was later put to a different use.) Furthermore, because "trailer" is defined under Conn. Gen. Stat. 14-1(a)(83) as "any rubber-tired vehicle without motive power drawn or propelled by a motor vehicle," trailers fit within the class of "commercial trucks, truck tractors, tractors and semitrailers, and vehicles used in combination therewith ." Storage trailers purchased separately from truck tractors therefore qualify for exemption under Conn. Gen. Stat. 12-412(70) if they have a gross vehicle weight rating in excess of 26,000 pounds, as long as they remain suitable for use on the road (for example, as long as the wheels of the trailers are not removed) to transport property.

RULING:

Trailers with a gross vehicle weight rating in excess of 26,000 pounds may be purchased or leased under the exemption in Conn. Gen. Stat. 12-412(70) as long as such trailers remain suitable for use on the road to convey property.

LEGAL DIVISION

Issued August 26, 1997

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