Are submittal drawings — engineering/CAD drawings similar to blueprints — subject to Kansas sales tax?

Plain-English summary

A company that installs building systems controlling lighting, heating, cooling, and security asked whether submittal drawings it buys are taxable. It described the drawings as similar to a blueprint — they map out the control system the company will install — and said the firm it hires performs only engineering or CAD (ACAD) work in producing them.

The Department's answer was no. It does not impose sales tax on blueprints, floor plans, or architectural or engineering consulting services. Because the submittal drawings, as described, resemble a blueprint closely enough, they fall within that same category of nontaxable items and services. So the submittal drawings, as defined in the request, are not taxable.

What this means for you

Contractors and system installers buying design drawings

Blueprint-like engineering or CAD drawings — submittal drawings that lay out a system to be installed — are not subject to Kansas sales tax, consistent with the Department's treatment of blueprints and architectural/engineering consulting services.

Engineering and CAD firms selling drawings

Producing blueprint-type drawings through engineering or CAD work is treated as a nontaxable service. Note the outcome turns on the drawings genuinely being blueprint-like design work; a different product could be analyzed differently.

Common questions

Q: Are submittal drawings taxable in Kansas?
A: No, where they resemble a blueprint and are produced through engineering or CAD work. The Department does not tax blueprints, floor plans, or architectural/engineering consulting services.

Q: Does it matter that a separate firm produces the drawings?
A: The key point is that the work is blueprint-like engineering/CAD work, which the Department treats as nontaxable.

Citations and references

• Kansas treatment of blueprints and design services — the Department stated it "does not impose sales tax on blue prints, floor plans and other architectural consulting services or engineering consulting services," and found submittal drawings sufficiently similar to a blueprint to be nontaxable. The ruling cites no specific statute section.

Source

• Landing page: Kansas Department of Revenue Policy Information Library
• Original document: P-2008-005

Original ruling text

Private Letter Ruling

Body:

Office of Policy & Research

October 15, 2008

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Dear XXXXXXXXX:

We wish to acknowledge receipt of your letter of October 2, 2008 regarding the application of Kansas Retailers’ Sales tax. You inquired regarding whether submittal drawings are taxable.

Your letter indicated you install systems in building which control functions such as lighting, heating, cooling and security within the structure. You pay a company to provide submittal drawings, which you identify as similar to a blue print. The submittal drawings map out the control system your company will install. The company you contract with performs only engineering or ACAD work in providing these submittal drawings.

The Department of Revenue does not impose sales tax on blue prints, floor plans and other architectural consulting services or engineering consulting services. Your description of submittal drawings indicates sufficient resemblance to a blue print to include such drawings within the scope of these nontaxable items and services. Therefore the submittal drawing, as defined in your letter, would not be taxable for sales tax purposes.

This private letter ruling is based solely on the facts provided in your request. If it is determined that undisclosed facts were material or necessary to make an accurate determination by the department, this ruling is null and void. This private letter ruling will be revoked in the future by operation of law without further department action if there is a change in the statutes, administrative regulations, or case law, or a published revenue ruling, that materially affects this private letter ruling.

Sincerely,

Jack Smith
Policy and Research

Date Composed: 10/15/2008 Date Modified: 10/15/2008

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