Is an insured armored courier's daily bank-delivery service subject to New York sales tax?

Plain-English summary

Cobert Banking Courier Corp. provides an insured courier service, using armored vehicles to make daily trips to banks on behalf of its customers. It asked whether this service is subject to New York sales tax.

Tax Law § 1105(c)(8) taxes "protective and detective services" broadly, and the statute specifically lists "armored car services" among the services covered -- alongside alarm/protective systems, detective agencies, and guard/patrol/watchman services. The Department pointed to its own prior published guidance (Important Notice N-90-20, on protective and detective services) confirming that armored car and bonded courier services fall within this taxable category. It also explained the sourcing rule for this kind of service: tax is based on where the protected property is actually delivered, not where it was originally picked up.

Applying that to Cobert's business: because Cobert makes daily armored-vehicle trips delivering customers' property to banks, its service is a taxable protective and detective service, and New York sales tax applies at the applicable rate wherever the delivery bank is located in New York -- regardless of where the courier picked up the property in the first place.

What this means for you

Armored car and courier services

If you provide armored transport or bonded courier delivery of cash, valuables, or similar property, expect your service charges to be taxable in New York as a protective and detective service. Track delivery destinations carefully, since that -- not the pickup point -- determines where and whether New York tax applies.

Banks and businesses using courier services

If your bank-delivery courier is based outside New York but delivers to a New York branch, expect the delivery leg of that service to be subject to New York sales tax based on the bank's location.

Accountants and tax professionals

This is a short, clean confirmation that armored car and bonded courier services are squarely within the § 1105(c)(8) protective and detective services category, plus a reminder that the taxing jurisdiction for this kind of service is the delivery point, not the pickup point -- useful for any client running a multi-state courier operation.

Common questions

Q: Does it matter where the courier picks up the property?
A: No -- the opinion is explicit that taxation is determined by the place where the protected items are delivered, regardless of the pickup location.

Q: Are all armored car and courier services taxable in New York?
A: This opinion confirms armored car and bonded courier services fall within the § 1105(c)(8) protective and detective services category and points to the Department's existing published guidance (N-90-20) on the same point.

Q: Can another courier company rely on this ruling?
A: No. This advisory opinion binds the Department only with respect to Cobert Banking Courier Corp. and the specific facts it described.

Citations and references

Statutes and regulations:

• Tax Law § 1105(c)(8) (tax on protective and detective services, including armored car services)
• Tax Law § 1110(a) (use tax on enumerated services)
• Important Notice N-90-20, "New York State Sales and Use Tax on Protective and Detective Services"

Prior rulings and cases referenced:

• None cited in this opinion.

Source

• Landing page: https://www.tax.ny.gov/pubs_and_bulls/advisory_opinions/sales_ao_1996.htm
• Opinion: https://www.tax.ny.gov/pdf/advisory_opinions/sales/a96_78s.pdf

Original ruling text

New York State Department of Taxation and Finance
TSB-A-96 (78) S
Sales Tax
December 16, 1996

Taxpayer Services Division
Technical Services Bureau

STATE OF NEW YORK
COMMISSIONER OF TAXATION AND FINANCE
ADVISORY OPINION

PETITION NO.S960816A

On August 16, 1996, a Petition for Advisory Opinion was received from Cobert Banking
Courier Corp., 2874 Lee Place, Bellmore, New York 11710.
The issue raised by Petitioner, Cobert Banking Courier Corp., is whether the service provided
by an insured courier making daily trips to banks for its customers, is subject to sales tax.
Petitioner submits the following facts as the basis for this Advisory Opinion. Petitioner
provides a service as an insured courier making daily trips to banks for customers. Petitioner uses
armored vehicles for its service.
Section 1105(c) of the Tax Law provides in part:
Imposition of sales tax. On and after June first, nineteen hundred seventy-one, there
is hereby imposed and there shall be paid a tax of four percent upon:
(c) The receipts from every sale, except for resale, of the following services:
*

*

*

(8) 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 any 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. (Emphasis
added.)
Section lll0(a) of the Tax Law provides in part:
Except to the extent that property or services have already been or will be subject to
the sales tax under this article, there is hereby imposed on every person a use tax for
the use within this state on and after June first, nineteen hundred seventy-one except
as otherwise exempted under this article ... (C) of any of the services described in
paragraphs (1), (7) and (8) of subdivision (c) of section eleven hundred five ....

-2­
TSB-A-96 (78) S
Sales Tax
December 16, 1996

In this case, Petitioner is an insured courier who makes daily trips for its clients to banks
using armored vehicles. Under Sections 1105(c)(8) and lll0(a)(C) of the Tax Law, protective and
detective services are subject to the New York State and local sales and use taxes. Protective and
detective services include armored car and bonded courier services. (See Important Notice entitled
"New York State Sales and Use Tax on Protective and Detective Services", N-90-2O.)
The application of the tax to armored car services and the services of bonded couriers is
determined by the place in which the items protected are delivered, regardless of where the items are
picked up.
Accordingly, Petitioner's services are subject to the New York State and local sales and use
taxes, at the applicable sales tax rate where customers' property is delivered to banks located in New
York State.

DATED: December 16, 1996

/s/
JOHN W. BARTLETT
Deputy Director
Technical Services Bureau

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