Is a cash-processing and armored-car money service taxable, and does bundling the charges make all of it taxable?

Plain-English summary

Paul J. Carucci sought guidance about a client's combined money-handling operation. The client uses an armored truck to carry a customer's money from the customer to a "money room," processes it there, and then delivers the prepared deposit to the bank. The money room's work is to count and package the cash, micro-encode and total the checks, verify the customer's total receipts, and prepare the bank deposit. Carucci asked which parts are taxable, and whether a combined bill makes everything taxable.

The Department drew a clean line:

• Armored-car transport is taxable. Section 1105(c)(8) taxes "protective and detective services," and the statute expressly lists "armored car services." So the transport is taxable "whether or not tangible personal property is transferred in conjunction therewith."
• The cash-room processing is not taxable. Counting, packaging, micro-encoding, totaling checks, verifying receipts, and preparing deposits are not among the services enumerated in Article 28 of the Tax Law, so they fall outside the sales tax.

How you bill matters. Under § 527.1(b), when taxable and exempt items are sold "as a single unit," tax is collected on the total price (the regulation's example: a package of cheeses, a cheese board, and a knife sold for one price is taxed on the whole $15). So:

• One combined charge for armored-car plus cash-room services → the entire charge is taxable.
• Separately billed armored-car service → only the armored-car portion is taxable, and the cash-room services stay exempt.

What this means for you

Enumerated services are taxable; everything else isn't

New York's sales tax on services is a list: if a service is specifically enumerated (like armored car service under § 1105(c)(8)), it's taxable; if it isn't on the list, it's generally not. Back-office cash processing — counting, encoding, verifying, deposit prep — isn't enumerated, so it escapes tax on its own.

Separate your taxable and exempt charges

This is the practical takeaway. Because § 527.1(b) taxes a bundled single-price sale on the full amount, mixing a taxable armored-car charge with exempt cash-room work under one line item pulls the exempt work into the tax base. Itemize the armored-car charge separately to keep the processing charges tax-free.

Applies to security and cash-logistics providers

Companies that combine transport with money-processing (armored carriers, cash-vault operators, retail cash-management services) should map each service to whether it's enumerated, then structure invoices so the exempt services are stated apart from the taxable transport.

Common questions

Q: Is armored car service taxable in New York?
A: Yes. It's an enumerated protective/detective service under § 1105(c)(8), taxable whether or not property changes hands.

Q: Is cash counting and deposit preparation taxable?
A: No. Those money-room services are not enumerated in Article 28, so they are not subject to sales tax.

Q: If I bill one price for both, is the whole thing taxable?
A: Yes. Under § 527.1(b), a single-unit charge covering taxable and exempt services is taxed on the total. Bill the armored-car service separately to tax only that part.

Citations and references

Statutes and regulations:

• Tax Law § 1105(c)(8) — tax on protective and detective services, including armored car services
• 20 NYCRR § 527.1(b) — taxable and exempt items sold as a single unit are taxed on the total price

Source

• Landing page: https://www.tax.ny.gov/pubs_and_bulls/advisory_opinions/sales_ao_1990.htm
• Opinion: https://www.tax.ny.gov/pdf/advisory_opinions/sales/a90_54s.pdf

Original ruling text

New York State Department of Taxation and Finance

Taxpayer Services Division
Technical Services Bureau

TSB-A-90(54)S
Sales Tax
October 24, 1990

STATE OF NEW YORK
COMMISSIONER OF TAXATION AND FINANCE
ADVISORY OPINION

PETITION NO. S900620A

On June 20, 1990 a Petition for Advisory Opinion was received from Paul J. Carucci, 9 Scott
Drive, New City, New York 10956.
The issue raised by Petitioner, Paul J. Carucci, is what part, if any, of its client's service of
counting money, deposit verification, and transportation of such money via armored truck is subject
to the tax imposed under Section 1105(c)(8) of the Tax Law; and if taxable, would its client be
required to collect the tax on the total amount if it issued a combined billing for both the
transportation and the cash room services.
Petitioner's client transports money via armored truck from the client's customer to a money
room, then from the money room to the bank. The primary service of the money room is to count and
package the cash, micro-encode and total the checks, verify the total receipts of the customer and
prepare the deposit to the banks.
Section 1105(c)(8) of the Tax Law imposes a tax upon:
Protective and detective services, including, but not limited to, all services provided
by or through alarm or protective systems of every nature, including, but not limited
to, protection against burglary, theft, fire, water damage or any malfunction of
industrial processes or other malfunction of or damage to property or injury to
persons, detective agencies, armored car services and guard, patrol and watchman
services of every nature other than the performance of such services by a port
watchman licensed by the waterfront commission of New York Harbor, whether or
not tangible personal property is transferred in conjunction therewith.
Armored car service is one of the services specifically subjected to the tax imposed under
Section 1105(c)(8) of the Tax Law. The service of counting, packaging cash, micro-encoding,
totaling checks, verifying total receipts, and preparing deposits to the bank are not services that come
within the scope of Article 28 of the Tax Law and are thus not subject to sales tax.
Section 527.1(b) provides that:
(b)
Taxable and exempt items sold as a single unit. When tangible
personal property, composed of taxable and exempt items is sold as a single unit, the
tax shall be collected on the total price.
TP-9 (9/88)

-2­
TSB-A-90(54)S
Sales Tax
October 24, 1990

Example:

A vendor sells a package containing assorted cheeses,
a cheese board and a knife for $15. He is required to
collect tax on $15.

In accordance with said regulation, if Petitioner's client charges a single price for all of its
services, the entire charge is subject to sales tax. However, if Petitioner's client bills its armored car
services separately from its cash room services, only the armored car services portion of the bill
would be subject to sales tax.

DATED: October 24, 1990

s/PAUL B. COBURN
Deputy Director
Taxpayer Services Division

NOTE: The opinions expressed in Advisory Opinions
are limited to the facts set forth therein.