Georgia State Tax Rulings
Free plain-English summaries of state tax letter rulings and advisory opinions issued in Georgia, with full citations and the original source on every page.
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Does a Georgia electric-vehicle charging-station operator collect sales tax when it bills drivers by charging time or by kilowatt-hour?
Time-based EV charging was not a taxable retail sale of electricity, so the operator did not collect sales tax from drivers and instead owed tax on property it consumed in providing the service. If pr…
Does a Georgia aircraft-painting company charge sales tax for stripping, sanding, and painting aircraft, and who pays tax on the materials?
No. Charges for stripping, sanding, and painting aircraft are non-taxable service charges because Georgia does not specifically tax those services. The aircraft painter is generally the consumer of pa…
Does a Georgia energy-savings company charge sales tax when it owns and installs efficiency equipment but bills customers only from measured utility savings?
No. Georgia treated the transaction as a non-taxable energy-savings service because customers sought measured cost savings, not the installed equipment; the provider owned and controlled the equipment…
How does Georgia sales tax apply to a senior-living facility's mandatory dining allowance and extra meal charges for long-term independent-living residents?
The mandatory dining allowance included in a long-term independent-living service fee was not taxable to the resident; the facility instead paid tax on food it bought to provide those meals. Charges f…
Are cost-reimbursement charges for donated, non-transplantable human tissue supplied for medical research and training subject to Georgia sales tax?
No. The Department determined that the described non-transplantable human tissue was not tangible personal property under Georgia's Sales and Use Tax Act. Reasonable cost-reimbursement charges for acq…
Are charges for a golf driving range, batting-cage tokens, and professional golf lessons subject to Georgia sales tax?
Driving-range charges and batting-cage token charges are taxable retail sales because customers pay to participate in games or amusement activities. Separately charged golf lessons from a professional…
Are charges for computer-based electronic messaging and data-distribution services subject to Georgia sales and use tax?
No. Georgia taxes services only when they are specifically listed as taxable, and data-distribution and electronic-messaging services are not on that list, so the provider's charges to customers are n…
Does a rewards-program operator owe Georgia tax on the tokens it sells to businesses, and on the machines, prizes, and tokens it buys out of state?
The token 'sales' are not taxable, but the out-of-state purchases are. The Department treats the rewards program as a nontaxable service, so the operator does not collect sales tax on the tokens it pr…
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These are official tax letter rulings and advisory opinions issued by Georgia's revenue authority in response to questions from specific taxpayers about how the tax law applies to their facts. A ruling is binding on the department only for the taxpayer who requested it and cannot be relied on by anyone else, but it is strong evidence of how the state reads the law. Every ruling above has a plain-English question and short answer, plus a link to the full original source.