Are monthly or annual golf-club membership dues exempt from South Carolina admissions tax?

Plain-English summary

South Carolina Revenue Ruling #24-4 explains the admissions-tax exemption enacted for annual or monthly dues paid to a golf club. South Carolina otherwise imposes a 5% admissions tax on paid admissions to places of amusement. Beginning May 13, 2024, membership dues paid to a club that offers golf are exempt from the state tax.

The exemption follows the nature of the membership, not every charge collected by the club. It covers monthly and annual golf-club membership dues, including an outside membership offered by a golf club when it provides access to golf at participating clubs. It does not cover green fees or driving-range fees, and it does not cover membership dues paid to a club that offers only tennis, pool access, or other non-golf amenities.

The effective date is firm. Dues paid before May 13, 2024 remained taxable, and the ruling says no refund is available for tax properly reported on those earlier payments. Golf clubs omit qualifying dues paid on or after May 13 from the state admissions-tax return.

What this means for you

Golf clubs

Separate exempt monthly and annual membership dues from taxable green fees, driving-range charges, and other admissions. For the May 2024 return, the dividing line is the payment date: qualifying dues paid on or after May 13 are excluded.

Members

The exemption applies when dues buy membership in a club that offers golf. A membership limited to tennis, a pool, or other non-golf access is outside the exemption even if it is called monthly or annual dues.

Clubs subject to county fees

Do not assume the state exemption controls a county admissions fee. The ruling says a county fee arises under county ordinance and directs taxpayers to consult the county about local treatment.

Common questions

Q: Are green fees exempt for members or nonmembers?
A: No. The exemption applies to monthly and annual golf-club membership dues, not green fees or driving-range fees.

Q: Does an outside-club membership qualify?
A: Yes, if the membership offered by the golf club includes access to golf at participating clubs.

Q: Can a club obtain a refund for tax paid on 2024 annual dues collected before May 13?
A: No. Those payments occurred before the exemption became effective and remained taxable.

Q: Does the state exemption automatically apply to a county admissions fee?
A: No. The county's ordinance governs, and the ruling recommends checking with that county.

Citations and references

• S.C. Code Ann. § 12-21-2420 — 5% admissions tax and the golf-club-dues exemption

Source

• Landing page: SC Advisory Opinion Search
• Original PDF: RR24-4.pdf

Original ruling text

STATE OF SOUTH CAROLINA

DEPARTMENT OF REVENUE
300A Outlet Pointe Blvd., Columbia, South Carolina 29210
P.O. Box 125, Columbia, South Carolina 29214-0575

SC REVENUE RULING #24-4

SUBJECT:

Golf Club Monthly or Annual Dues
(Admissions Tax)

EFFECTIVE DATE:

May 13, 2024

MODIFIES:

S.C. Private Letter Ruling #91-5
S.C. Revenue Ruling #91-18
S.C. Revenue Ruling #05-14

SUPERSEDES:

All previous advisory opinions and any oral directives in
conflict herewith.

REFERENCES:

S.C. Code Ann. § 12-21-2420

AUTHORITY:

S.C. Code Ann. § 12-4-320
S.C. Code Ann. § 1-23-10(4)
SC Revenue Procedure #09-3

SCOPE:

The purpose of a Revenue Ruling is to provide guidance to the public.
It is an advisory opinion issued to apply principles of tax law to a set
of facts or general category of taxpayers. It is the Department’s
position until superseded or modified by a change in statute,
regulation, court decision, or another Department advisory opinion.

S.C. Code Ann. § 12-21-2420 imposes an admissions tax of five percent (5%) upon all paid
admissions to places of amusement within this State. On May 13, 2024, Governor Henry
McMaster signed Bill Number H. 3880 (“Act”), which amends S.C. Code Ann. § 12-21-2420 to
exempt from admissions tax “annual or monthly dues paid to a golf club.” The purpose of this
advisory opinion is to address questions concerning the scope of this exemption.

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1. What type of dues are exempt? Does the exemption apply to other dues processed
by golf clubs?
The Act exempts monthly and annual membership dues paid to a golf club from the
state’s admissions tax. Accordingly, any membership dues that are paid to a golf club are
exempt from the state’s admissions tax. However, the exemption does not apply to
monthly or annual membership dues paid to a club which does not offer golf. For
example, the exemption does not apply to a location which only offers a membership to
play tennis and/or access a pool. (See also Response No. 6 concerning dues that allow
members to play golf at other locations.)

2. Will the exemption apply to any local admissions taxes or fees imposed by counties?
   A local admissions fee is imposed under a county ordinance and is governed by the
   county. Taxpayers are encouraged to consult with the county in which the local
   admissions fee is imposed to determine whether the golf club membership dues are
   exempt from the local admissions fee.
3. Does the exemption apply to green fees or driving range fees charged to both
   members and non-members?
   No. The Act exempts golf club membership dues, both monthly and annual, from the
   State admissions tax. It does not exempt other fees, including green fees or driving range
   fees. For example, the state’s admissions tax still applies when a semi-public golf club
   charges a greens fee to non-members.
4. Will a refund be issued for admissions tax already reported and paid for annual
   membership dues billed and collected from members for 2024?
   No. The Governor signed the Act on Monday, May 13, 2024, and it became effective on
   that day. When golf clubs file their admissions tax return for May, they will not need to
   include any annual or monthly dues paid on or after May 13, 2024. However, because
   the exemption was not available before the effective date of the Act, any dues paid before
   May 13, 2024 were subject to the tax and no refund is available.
5. When will golf clubs no longer need to report/submit admissions tax on monthly or
   annual membership dues?
   The Act was signed by the Governor on Monday, May 13, 2024, and became effective
   that day. When golf clubs file their admissions tax return for May, they will not need to
   include any annual or monthly dues paid on or after May 13, 2024.

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6. Does the exemption apply to outside memberships that golf clubs may offer to their
members, which allows their members to receive benefits at other participating
clubs?
The Act exempts golf club membership dues, both monthly and annual, from the State
admissions tax. If the outside memberships offered by golf clubs to their members
include access to golf, then the membership dues are exempt from the tax.

SOUTH CAROLINA DEPARTMENT OF REVENUE

s/W. Hartley Powell
W. Hartley Powell, Director
July 11
, 2024
Columbia, South Carolina

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