South Carolina State Tax Rulings
Free plain-English summaries of state tax letter rulings and advisory opinions issued in South Carolina, with full citations and the original source on every page.
No South Carolina rulings match these filters
Try a different search term or clear the filters.
Did PLR 98-3 include a supermarket's purchase-based supplier allowances in taxable gross proceeds when customers used its loyalty card?
No. The supplier allowances were based on the retailer's past purchases or negotiations, not on particular customer sales, so they were outside gross proceeds. Tax applied to the discounted amount the…
Were coronary stents, catheters, guide wires, and angioplasty accessories exempt when sold to South Carolina hospitals?
No. The listed coronary stents, catheters, guide wires, and angioplasty accessories were taxable when sold to hospitals. Hospitals consumed them while providing medical services, and a stent was not a…
Who owed South Carolina sales or use tax when a retailer had a manufacturer or distributor drop-ship goods to its customer?
The retailer owed sales tax if engaged in business in South Carolina. A voluntarily licensed remote retailer collected use tax. If the retailer had neither South Carolina business activity nor a licen…
Did PLR 98-1 impose South Carolina sales or use tax on a digital imaging company's electronic work for newspaper advertising inserts?
No. On the stated facts, the imaging company produced and transferred images entirely electronically and delivered no tangible personal property in South Carolina, so its charges were not subject to s…
Were utility late-payment fees finance charges excluded from South Carolina taxable gross proceeds under RR 98-4?
No. RR 98-4 treated electric, cable, and telephone late-payment fees as default charges rather than finance charges, so they entered taxable gross proceeds. RR 09-6 later superseded this ruling and ex…
Under RR 97-23, was buying a prepaid telephone calling card taxable, and when did tax apply to calls made with it?
The card purchase was not taxable because it represented an intangible future right to telephone service. Under the ruling's 1997 rules, tax arose when the card was used: local South Carolina calls we…
When did RR 97-20 treat a local fee or tax as part of gross proceeds subject to South Carolina state sales tax?
A local hospitality tax or qualifying local accommodations fee was included in gross proceeds when imposed on the retailer and passed through as the retailer's receipt. It was excluded when imposed on…
Did PLR 97-6 impose South Carolina sales tax on mobile homes sold with the land as part of a mobile home park?
No. The mobile homes were fixtures and therefore real property because their wheels were removed, they sat on permanent foundations, they were connected to utilities, and their porches, additions, and…
How did PLR 97-5 tax commercial security monitoring when equipment was sold or separately rented, and how were installation and repairs treated?
Monitoring fees were not taxable communications charges. Equipment sold to the customer was taxable, and a separately stated periodic charge for provider-owned equipment was a taxable rental. Reasonab…
How did PLR 97-4 tax residential alarm monitoring, provider-owned standard equipment, customer-owned add-ons, installation, and repairs?
Periodic charges for the provider-owned standard package and burglary/fire monitoring were not taxable because the true object was a nontaxable monitoring service, so the provider paid tax when buying…
Were city or county cable-franchise fees included in taxable gross proceeds when passed through to South Carolina cable customers?
Yes. RR 97-10 said a city or county cable-franchise fee calculated as a percentage of the cable system's gross receipts was included in taxable gross proceeds, whether the customer bill stated the fee…
Under the superseded RR 97-6, what material-handling equipment and investments qualified for South Carolina's sales-tax exemption?
The exemption covered systems, equipment, racks, and repair parts used in distribution or manufacturing facilities when the taxpayer gave advance notice and invested at least $35 million in South Caro…
Under RR 97-5, how much South Carolina sales tax did a nonresident owe when buying a travel trailer?
With the required notarized form, tax was the lesser of the buyer's home-state tax or South Carolina's then-applicable amount: 5% of price after trade-in or $300. No South Carolina tax was due if the …
Under the superseded RR 97-3, how were hotel room charges, mandatory fees, optional guest services, and tourist packages taxed?
Room charges and mandatory customary services generally used the ruling's 7% accommodations rate. Optional services often used a 5% guest-charge rate or another tax rule. RR 98-21 expressly superseded…
Under the superseded RR 97-1, when did firefighting equipment share a fire truck's $300 maximum sales or use tax?
Equipment shared the truck's $300 cap only when necessary for it to be a fire truck, sold by the same vendor, and mounted or stowed before the buyer took title or possession. Otherwise the equipment w…
When did superseded RR 96-8 include a city or county tourism or restaurant fee in taxable gross proceeds?
A fee imposed on the restaurant or hotel was the retailer's receipt and expense, so an amount recovered from the customer entered taxable gross proceeds. A fee legally imposed on the customer was excl…
Did RR 96-3 impose South Carolina sales or use tax when software was delivered entirely by modem and telephone line with no physical media?
No. Software delivered entirely by modem and telephone line, with no diskette, tape, or other physical copy, was intangible software rather than taxable tangible personal property. The transmission sy…
Were fencing, watering tubs, feed troughs, and hay feeders exempt for commercially raised poultry and livestock under RR 95-11?
Yes. RR 95-11 exempted fencing and fencing supplies used to enclose poultry or livestock raised or maintained for commercial purposes, whether inside a barn or around a dedicated field. Watering tubs,…
What South Carolina income, sales, and deed-tax consequences did RR 95-9 assign to a partnership's conversion into an LLC?
For a conversion with the same owners, ownership shares, and business, RR 95-9 treated the LLC as a continuation of the partnership. The partnership did not terminate or close its tax year, no new tax…
Were blood glucose meters exempt from South Carolina sales and use tax under PLR 95-6?
Yes, for the addressed taxpayer when a blood glucose meter was sold to a diabetic under a physician's authorization and direction. The Department treated the meter as a technological development servi…
Which restaurant purchases were taxable or exempt from South Carolina sales and use tax under RR 95-6?
RR 95-6 treated food and beverage ingredients and qualifying containers or packaging used to sell and deliver the meal as nontaxable wholesale or exempt purchases. It treated supplies consumed by the …
Who owed South Carolina sales and use tax under PLR 95-4 when a food-service company managed hospital or private-company cafeterias?
For the addressed contracts, the food-service company made a nontaxable wholesale sale when it supplied food to a hospital and provided a nontaxable service when the hospital bought the food itself; t…
Did RR 94-11 extend South Carolina's school and public-library book exemptions to alternative media?
Yes. Qualifying school and public-library books, periodicals, and newspapers remained exempt when supplied on media such as audio or video tape, CD-ROM, microfilm, or microfiche. The ruling did not ad…
Did PLR 94-11 apply South Carolina's historical $300 maximum tax to a research electron microscope?
Yes. Each item of the electron-microscope system qualified because it was used directly and exclusively to develop or improve membrane-filter applications and was located in a separate facility devote…
How did PLR 94-10 tax an out-of-state fabricated ornamental railing installed at a South Carolina dealership?
The ruling classified the railing as a unique product. Materials used to fabricate it out of state were not taxed because they were not sold and delivered to the contractor in South Carolina, but inst…
Did PLR 94-7 exempt grease and oil used to lubricate tax-exempt manufacturing machinery?
No. The ruling treated the lubricants as taxable purchases for ABC's own use, not exempt machine parts or purchases for resale. Later burning the used oil as boiler fuel, recycling it, selling it, or …
Were meals sold to students by the nonprofit K-12 school in PLR 94-6 exempt from South Carolina sales tax?
Yes. The school's cafeteria meals qualified because they were sold to kindergarten-through-twelfth-grade students, within the school setting, and the meal program was operated without profit.
Did PLR 94-3 tax gravel, crushed rock, and asphalt that a road contractor produced for its own projects?
Not on the stated facts. Removing gravel and rock from ABC's own land was not a retail sale, and its rare asphalt sales did not make it an asphalt manufacturer. If regular sales later made ABC a manuf…
How did PLR 94-4 tax a food-service company selling university meal plans as the school's agent?
The ruling treated unprepared food bought for board-plan meals as taxable retail purchases and treated separate meal or food sales as taxable retail sales. For shared inventory, the agent bought whole…
How did RR 94-2 tax standard and custom-fabricated building products used by their maker in construction contracts?
A true manufacturer regularly selling standard finished products owed tax on fair market value when it used those products at a South Carolina job site. A contractor fabricating unique, job-specific p…
When did PLR 94-2 treat a federal security contractor's purchases as exempt federal-government purchases?
The purchases were exempt when ABC bought on the federal government's behalf, did not risk its own credit, disclosed the government agency on purchase orders, vested title in the government, and paid …
Which South Carolina bodies counted as legislative agencies for the temporary document-copy sales-tax exemption in RR 94-1?
RR 94-1 limited the temporary exemption to agencies under the South Carolina Legislature's direct control, such as the Senate, House, joint committees, Legislative Audit Council, Legislative Council, …
Did PLR 94-1 impose South Carolina sales, use, or property tax on equipment sold for foreign resale and temporarily stored in-state?
No, on the stated facts. The sale to the foreign company was a wholesale sale for resale, and the equipment remained exempt inventory while temporarily stored in South Carolina before export.
Did South Carolina PLR 93-6 apply the historical $300 maximum tax to each item in a university supercomputer system used for research and development?
Yes. Each item qualified because the system was used exclusively to develop software and other R&D products and was housed in a restricted, separately staffed facility devoted exclusively to research …
How did South Carolina Revenue Ruling 93-9 apply sales and use tax to meals furnished or sold by colleges, hospitals, and their food-service companies?
Institutional meals were taxable at different transaction points: food inputs used for board-plan or patient meals were retail purchases, while separate cash food sales were taxable retail sales by th…
Under South Carolina PLR 93-5, were sales of Lupron exempt when dispensed by a pharmacist or sold by the manufacturer to a physician for administration?
A licensed pharmacist's sale of Lupron under a medical professional's prescription was exempt. LOP's sale to a physician who would administer the drug was taxable because the doctor was the consumer a…
Did South Carolina PLR 93-4 exempt a commercial fisherman's retail oyster sales as farm products?
Yes, but only for oysters the fisherman cultivated and harvested in his own shellfish-culture permit area and sold in their original state of production or preparation. Oysters harvested from state-ma…
How did South Carolina Revenue Ruling 93-8 tax basic horse and stock trailers compared with trailers containing a camper package?
Basic trailers, tack- or dressing-room trailers, and goosenecks without camper packages were taxed at the full 5% historical rate. A trailer with a camper package paid the lesser of 5% or $300.
Under South Carolina Revenue Ruling 93-6, when were charges for extended warranties subject to sales or use tax?
A warranty sold with tangible personal property was taxable in full, even if optional and separately stated. A separate warranty bought after the property sale was not subject to sales or use tax.
Did South Carolina PLR 93-1 exempt printing inputs used to produce a free advertising shopper that was not a newspaper?
Mostly no. Because the shopper was distributed free and was not a newspaper, newsprint, ink, composing supplies, press plates, photo negatives, production electricity, and local telephone service were…
When did South Carolina Revenue Ruling 93-4 treat computer-software maintenance and support contracts as taxable?
A maintenance contract sold with software was fully taxable, whether optional or mandatory. A separately sold or later contract was taxable when its true object was software or updates, but not when i…
Which extra automobile-rental charges did RR 93-1 include in taxable gross proceeds?
All listed add-ons were taxable: fuel charges, collision-damage waivers, personal-accident coverage, extended liability protection, personal-effects coverage, and combined accident/effects coverage. S…
Were ABC's Advantage Card and Business Card warehouse-club membership fees subject to South Carolina sales tax under PLR 92-11?
Yes. The paid membership fees were part of the consideration for buying merchandise because Advantage Card and Business Card members paid the posted wholesale price, while 90-day free members paid tha…
Did SC PLR 92-10 impose sales or use tax when exempt manufacturing machines were sold to a lessor and leased back to the manufacturer?
No. The sale to the lessor, the lease back to ABC, and ABC's continued use of the machines were exempt because the equipment was used to manufacture tangible personal property for sale. The ruling sai…
How did South Carolina Revenue Ruling 92-5 apply sales and use tax to vending-only businesses and businesses also making counter sales?
A vending-only operator generally paid tax when buying inventory. A business also making counter sales could buy common inventory for resale, then report vending withdrawals and counter sales separate…
Which restaurant purchases did South Carolina Revenue Ruling 92-3 treat as tax-free resale or packaging items, and which as taxable supplies?
Food, beverage ingredients, and containers or wrapping used to sell and deliver them were generally tax-free. Napkins, straws, utensils, cleaning items, furniture, office supplies, and other operating…
Under SC Revenue Ruling 91-20, when was a tax preparer's electronic-filing charge subject to sales tax?
When the same preparer prepared and electronically filed the return, the filing was incidental to the nontaxable preparation service and the combined charge was not taxable. When the preparer only tra…
When did SC Revenue Ruling 91-9 tax lease payments for tangible personal property delivered in or later brought into South Carolina?
In-state delivery from a South Carolina lessor made every lease payment taxable even if the lessee immediately moved the property out of state. Lessor-required out-of-state delivery made the payments …
Which components of a municipal water-treatment-plant expansion qualified for the manufacturing-machine sales-tax exemption under SC RR 91-8?
Equipment within the processing window—from the rapid-mix tank through final filtration—generally qualified, including mixers, flocculators, sludge machinery, processing piping, filter tanks, media fi…
How did SC Revenue Ruling 91-3 tax hotel-guest valet laundry charges, the cleaner's charge to the hotel, and cleaning of hotel-owned linens?
The independent cleaner's charge to a hotel for cleaning a guest's clothing was a nontaxable wholesale sale for resale. The hotel's valet-service charge to the guest was a taxable additional guest cha…
Did South Carolina sales or use tax apply when a company nominally sold equipment and leased it back but retained title, possession, costs, and risk of loss?
No. The purported equipment sale and leaseback were a financing arrangement, not an actual sale and lease, because ABC retained legal title, possession, ownership costs, risk of loss, and tax ownershi…
When did SC Revenue Ruling 90-6 tax video-rental club membership fees and late-return charges?
A video-club membership fee was taxable when it entitled the customer to free or discounted movie or VCR rentals. A fee serving only as a security-deposit substitute or nominal processing charge, with…
Were time-based charges for accessing an out-of-state computer research database over telephone lines subject to South Carolina sales and use tax?
Yes. Charges for computer database access time were taxable as charges for transmitting messages through a modem and telephone lines. XYZ became liable for sales and use tax on those charges effective…
Under South Carolina's 1989 guidance, did a hotel owe sales and accommodations tax on separately billed local calls, long-distance calls, and pay-per-view movies?
Yes. Separately billed local calls, long-distance calls, and pay-per-view movies were components of the accommodation price and were subject to both sales and accommodations tax. Telephone service sol…
Could a South Carolina retailer deduct an early-payment cash discount after reporting sales tax on the full price in the month of sale?
Yes. The retailer first had to report tax on the full sales price for the month in which the sale occurred. If the customer later paid within the discount period and actually took the allowed cash dis…
Were separate computer hardware and software maintenance fees subject to South Carolina use tax under PLR 89-6?
The hardware maintenance fee was not taxable because it was a separately purchased service and was not part of the equipment lease. The software support fee was taxable because the software was delive…
Were aircraft engines and parts taxable when installed in South Carolina but delivered by the seller with the aircraft to the buyer in North Carolina?
No. ABC installed the engines and parts in South Carolina but retained control of them and delivered the aircraft to the buyer in Charlotte, North Carolina. Because transfer did not occur in South Car…
Were catalogs printed and mailed from South Carolina taxable when sent to the out-of-state retailer's customers inside and outside South Carolina?
Catalogs mailed to South Carolina residents were taxable; catalogs mailed to residents of other states were exempt under the out-of-state delivery rule. For the taxable South Carolina copies, gross pr…
Were plastic bags, corrugated cartons, and fiber drums supplied to medical-waste customers exempt as containers used to deliver tangible personal property?
No exemption applied. ABC was the end user of the bags, cartons, and drums in its waste-disposal service. The container exemption covered packaging used incident to the sale and delivery of tangible p…
Were a volunteer Coast Guard-related auxiliary and its separate nonprofit National Board exempt from South Carolina sales and use tax?
No. The volunteer civilian auxiliary was not a federal instrumentality, so its sales and purchases were taxable. Its separate National Board also was taxable because South Carolina gave charitable and…
Browse South Carolina rulings by topic
These are official tax letter rulings and advisory opinions issued by South Carolina's revenue authority in response to questions from specific taxpayers about how the tax law applies to their facts. A ruling is binding on the department only for the taxpayer who requested it and cannot be relied on by anyone else, but it is strong evidence of how the state reads the law. Every ruling above has a plain-English question and short answer, plus a link to the full original source.