Who must collect Louisiana sales tax when a short-term vehicle rental is arranged through a peer-to-peer sharing platform?

Plain-English summary

A peer-to-peer vehicle-sharing platform that connects vehicle owners with short-term drivers, approves transactions, and collects rental charges is a Louisiana dealer. Louisiana Revenue Ruling 23-001 therefore requires the platform to collect and remit both state and local sales or lease tax on rentals it facilitates.

The March 9, 2026 revision states a 5% Louisiana state tax on leases and rentals of tangible personal property. State tax must be filed and paid electronically to the Louisiana Department of Revenue unless the platform uses the marketplace-facilitator route described in the ruling. Local tax goes to the appropriate local collector.

Beginning July 1, 2025, peer-to-peer vehicle-sharing businesses were no longer categorically excluded from marketplace-facilitator treatment. A platform that meets the marketplace-facilitator definition may remit through the Louisiana Sales and Use Tax Commission for Remote Sellers. The ruling says Commission remittance becomes mandatory when the facilitator's Louisiana-delivery sales or facilitated revenue exceeds $100,000 in the current or previous calendar year.

Why the platform is the dealer

Company T did not own or rent the vehicles itself. It operated an online platform where:

• third-party owners listed available vehicles and set the base rental fee;
• drivers selected vehicles for short-term Louisiana use;
• the platform approved the transaction; and
• the platform collected rental fees and charges for items such as insurance, protection plans, and optional services.

Louisiana's dealer definition includes a person that operates, maintains, or facilitates a peer-to-peer vehicle-sharing program and collects part of the amount paid under a sharing agreement. Company T met that definition even though ownership and possession passed directly between the owner and driver.

The listed vehicles were "shared vehicles," the owners were "shared vehicle owners," and the renters were "shared vehicle drivers" under the ruling's statutory definitions. That classification made Company T responsible for tax collection on the facilitated rentals.

Tax rate and taxable event

The ruling describes a lease or rental as paid possession or use of tangible personal property without a transfer of title.

Tax was due when the driver possessed or used the vehicle in Louisiana. It did not matter where the lease agreement was made or where the owner first transferred possession.

The March 2026 revision applies a combined 5% state sales and lease tax under La. R.S. 47:302(B), 321(B), 321.1(B), and 331(B).

Where the platform remits tax

State tax

A dealer covered by the ruling must electronically file and remit state tax to the Louisiana Department of Revenue under La. R.S. 47:303(I), unless it properly uses the Commission route available to marketplace facilitators.

Local tax

The platform must also collect local sales tax and remit it to the appropriate local sales-tax collector. The ruling points businesses to the Uniform Local Sales Tax Board for local-collector information.

Remote Sellers Commission after July 1, 2025

Before July 1, 2025, Louisiana law excluded businesses facilitating rental cars from the marketplace-facilitator definition, so they could not file or remit through the Louisiana Sales and Use Tax Commission for Remote Sellers.

Act 433 of the 2025 Regular Session repealed that exclusion. From July 1, 2025 forward:

• a vehicle-sharing dealer that also meets the marketplace-facilitator definition may choose Commission remittance below the threshold; and
• Commission remittance is required once its gross revenue from Louisiana-delivery sales made or facilitated exceeds $100,000 in the current or prior calendar year.

Revision history matters

The official PDF says the ruling was revised twice:

• May 1, 2024: automobile-rental-tax provisions were removed; and
• March 9, 2026: the ruling was updated for Act 433 of 2025, changes in the tax rate, and repeal of the marketplace-facilitator prohibition.

Use the March 9, 2026 text rather than an earlier copy of RR 23-001.

What this means for you

Peer-to-peer vehicle-sharing platforms

Treat the platform as the collecting dealer for Louisiana rentals. Configure checkout to collect the applicable state and local tax and monitor the $100,000 marketplace threshold.

Vehicle owners using a platform

The ruling assigns collection and remittance to the platform on transactions it facilitates. Confirm that the platform handles Louisiana tax rather than assuming the owner must remit it separately.

Accountants and tax teams

Keep state and local remittance paths distinct, and document when the platform first crosses the Commission threshold using current- and prior-calendar-year Louisiana revenue.

Common questions

Q: Does the platform avoid dealer status because it never owns the cars?

A: No. Facilitating the sharing program and collecting part of the payment brought Company T within Louisiana's dealer definition.

Q: What state rate does the revised ruling state?

A: 5% on the Louisiana lease or rental of tangible personal property.

Q: Is tax due only if the rental contract was signed in Louisiana?

A: No. The ruling bases tax on possession or use of the leased vehicle in Louisiana, regardless of where the contract was made or possession was transferred.

Q: Where is local tax paid?

A: To the appropriate local sales-tax collector, unless the platform is remitting through the Commission under the post-July 1, 2025 marketplace rules.

Q: When is Commission remittance required?

A: When a marketplace facilitator has more than $100,000 of gross revenue from sales made or facilitated for Louisiana delivery during the current or previous calendar year.

Citations and references

• La. R.S. 47:301(4)(l) — dealer and peer-to-peer vehicle-sharing definitions
• La. R.S. 47:301(7)(a) — lease or rental definition
• La. R.S. 47:302(B), 321(B), 321.1(B), and 331(B) — 5% state lease tax described in the revised ruling
• La. R.S. 47:303(I) — electronic filing and remittance
• La. R.S. 47:340.1(A)(4)(b)(iv) — marketplace-facilitator exclusion repealed by Act 433 of 2025
• La. Admin. Code 61:I.4303(B) — possession or use of leased property in Louisiana
• LAC 61:III.101(C) — Revenue Ruling authority and reliance statement

Source

• Landing page: Louisiana Department of Revenue Policies
• Original PDF: LA Revenue Ruling 23-001, revised March 9, 2026

Original ruling text

Revised March 9, 2026 to reflect changes in the law enacted by Act 433 of the 2025 Regular
Session
Revenue Ruling No. 23-001 1
Sales and Use Tax
Peer-to-Peer Vehicle Sharing Platforms:
Tax Collection and Remittance Requirements
Purpose
The purpose of this ruling is to explain the tax collection and remittance requirement for
vehicle lease or rental transactions facilitated through peer-to-peer vehicle sharing
platforms.
Facts

Company T operates an online platform that connects third-party vehicle owners with
drivers/renters who want to lease or rent vehicles on a short-term basis for use in Louisiana.
Through Company T’s platform, vehicle owners provide listing information and set the base
rental fee for their vehicles. Prospective drivers view listings of available vehicles on
Company T’s platform. After a vehicle is selected, Company T approves the transaction and
collects rental fees and any other charges (e.g., insurance, protection plans, and other
optional services) from the driver. The driver then uses the shared vehicle for a set amount
of time for a set fee pursuant to a vehicle sharing agreement which sets forth the terms and
conditions agreed upon by the owner and driver. Company T does not own or rent vehicles;
Company T facilitates, via its online platform, the lease or rental of vehicles between vehicle
owners and drivers in Louisiana.
Issue

What are Company T’s tax collection and remittance obligations for vehicles leased or rented
by owners to drivers through Company T’s platform?
1 Revised May 1, 2024, to remove provisions related to the Automobile Rental tax. Further revised March 9,

2026 to reflect changes in the tax rate and the repeal of law prohibiting peer-to-peer vehicle sharing
platforms from being marketplace facilitators.

A Revenue Ruling is issued under the authority of LAC 61III.101(C). A Revenue Ruling is written to provide
guidance to the public and to Department of Revenue employees. It is a written statement issued to apply
principles of law to a specific set of facts. A Revenue Ruling does not have the force and effect of law and is not
binding on the public. It is a statement of the department's position and is binding on the department until
superseded or modified by a subsequent change in statute, regulation, declaratory ruling, or court decision.

Revenue Ruling 23-001
Page 2 of 4

Applicable Law and Definitions
Louisiana Revised Statutes 47:302(B), 321(B), 321.1(B), and 331(B), collectively, impose a
state sales and lease tax of 5.00% on the lease or rental within Louisiana of each item or
article of tangible personal property. “[L]ease or rental” is defined as the possession or use
of tangible personal property by a lessee or renter, for a consideration, without transfer of
title of such property. 2 Lease tax is due when a lessee possesses or uses leased tangible
personal property within Louisiana, regardless of where the lessor and lessee entered into
the lease contract or where the lessor transferred possession of the leased property to the
lessee. 3

Act 278 of the 2020 Regular Session, added R.S. 47:301(4)(n)(i) and expanded the definition
of “dealer” to include anyone who operates, maintains, or facilitates a peer-to-peer vehicle
sharing program and collects some portion of the amount paid under a vehicle sharing
program agreement. 4 Additional definitions enacted by Act 278, and now found in R.S.
47:301(4)(l)(ii), and are as follows:
1. Peer-to-peer vehicle sharing - the authorized use of a vehicle by a person other than
the vehicle's owner through a peer-to-peer vehicle sharing program

2. Peer-to-peer vehicle sharing program – a business platform that connects a shared
   vehicle owner with a shared vehicle driver to enable the sharing of vehicles for
   financial consideration

3. Shared vehicle - a vehicle that is available for sharing through a peer-to-peer vehicle
   sharing program

4. Shared vehicle driver - a person who has been authorized to drive the shared vehicle
   by the shared vehicle owner under a vehicle sharing program agreement

5. Shared vehicle owner - the registered owner, or a person or entity designated by the
   registered owner, of a shared vehicle made available for sharing to shared vehicle
   drivers through a peer-to-peer vehicle sharing program

6. Vehicle sharing program agreement - the terms and conditions applicable to a shared
   vehicle owner and a shared vehicle driver that govern the use of a shared vehicle
   through a peer-to-peer vehicle sharing program.
   2 La. R.S. 47:301(7)(a).

3 La. Admin. Code 61:I.4303(B), which further provides that lease and rental are synonymous.
4 La. R.S. 47:301(4)(n) has been renumbered as La. R.S. 47:301(4)(l).

A Revenue Ruling is issued under the authority of LAC 61III.101(C). A Revenue Ruling is written to provide
guidance to the public and to Department of Revenue employees. It is a written statement issued to apply
principles of law to a specific set of facts. A Revenue Ruling does not have the force and effect of law and is not
binding on the public. It is a statement of the department's position and is binding on the department until
superseded or modified by a subsequent change in statute, regulation, declaratory ruling, or court decision.

Revenue Ruling 23-001
Page 3 of 4

Until June 30, 2025, La. R.S. 47:340.1(A)(4)(b)(iv) excluded any person who offers or
facilitates the furnishing of rental cars by rental car companies from the definition of
marketplace facilitator. La. R.S. 47:340.1(A)(4)(b)(iv) was repealed by Act 433 of the 2025
Regular Session.
Analysis

Sales Tax
Company T is in the business of operating, maintaining, and facilitating an online platform
that connects vehicle owners with drivers who want to lease or rent vehicles on a short-term
basis for use in Louisiana. Its business platform connects “shared vehicle owners” with
“shared vehicle drivers” to enable the sharing of vehicles for financial consideration. Vehicle
means every device in, upon, or by which any person, property or thing is or may be
transported or drawn upon a public highway except devices moved by human power or used
exclusively upon stationary rails or track.

The available vehicles listed on Company T’s platform are “shared vehicles” because they are
made available for sharing to renters who wish to lease a vehicle through the platform. The
owners are “shared vehicle owners” as they are registered owners of vehicles that are made
available for sharing to shared vehicle drivers through a peer-to-peer vehicle sharing
program. Likewise, the drivers are “shared vehicle drivers” as they are persons who have
been authorized to drive shared vehicles by the shared vehicle owners under vehicle sharing
program agreements.
Through its operation, maintenance, and facilitation of a peer-to-peer vehicle sharing
program, Company T meets the definition of a dealer. As part of its collection of a portion of
the amount paid under the vehicle sharing program agreements, Company T must also
collect and remit sales tax on transactions facilitated on its vehicle sharing platform.
Reporting and Remittance

State sales tax 5 collected by dealers subject to this ruling is required to be electronically
remitted and paid to the Louisiana Department of Revenue. The local sales tax collected on
the same transactions must be remitted to the appropriate local sales tax collector. 6
Prior to July 1, 2025, these businesses were statutorily excluded from the definition of
marketplace facilitator and were ineligible to file or remit to the Louisiana Sales and Use Tax
Commission for Remote Sellers.
5 La. R.S. 47:303(I) requires dealers as defined by La. R.S. 47:301(4)(l) to file their sales tax returns

electronically and remit the related sales taxes electronically to the Department.
The Uniform Local Sales Tax Board maintains information related to the local sales tax on their website.

6

A Revenue Ruling is issued under the authority of LAC 61III.101(C). A Revenue Ruling is written to provide
guidance to the public and to Department of Revenue employees. It is a written statement issued to apply
principles of law to a specific set of facts. A Revenue Ruling does not have the force and effect of law and is not
binding on the public. It is a statement of the department's position and is binding on the department until
superseded or modified by a subsequent change in statute, regulation, declaratory ruling, or court decision.

Revenue Ruling 23-001
Page 4 of 4

Beginning July 1, 2025, dealers who meet the definition of marketplace facilitator under La.
R.S. 47:301(A)(3) also have the option of remitting to the Louisiana Sales and Use Tax
Commission for Remote Sellers (Commission). Remittance to the Commission is required
when the marketplace facilitator has gross revenues of more than $100,000 for sales made
or facilitated for delivery in Louisiana during the previous or current calendar year.
Ruling

Company T is a dealer pursuant to La. R.S. 47:301(4)(l)(i) and is responsible for collecting
and remitting the state and local sales tax on vehicles rented or leased pursuant to Company
T’s platform.

Questions regarding this guidance can be directed to [email protected]. Questions
concerning the collection, reporting, and remittance of state sales/lease tax can be directed
to [email protected].
Jarrod J. Coniglio
Secretary

A Revenue Ruling is issued under the authority of LAC 61III.101(C). A Revenue Ruling is written to provide
guidance to the public and to Department of Revenue employees. It is a written statement issued to apply
principles of law to a specific set of facts. A Revenue Ruling does not have the force and effect of law and is not
binding on the public. It is a statement of the department's position and is binding on the department until
superseded or modified by a subsequent change in statute, regulation, declaratory ruling, or court decision.