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.
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Did a West Virginia resident owe South Carolina sales tax on a car bought from a South Carolina dealer, and could the buyer claim a refund of tax paid?
No South Carolina sales tax was due because West Virginia did not impose sales tax on motor-vehicle sales; its separate 5% title privilege tax did not count. The buyer could not claim the refund direc…
Did an out-of-state clearinghouse that routed telephone billing records and payments owe South Carolina tax on communications charges?
No. XYZ did not furnish communications in South Carolina and therefore was not liable under section 12-35-1150. South Carolina retailers that actually provided communication services owed the tax, exc…
Were hotel charges to federal employees taxable when the employee paid personally and was later reimbursed by the government?
It depended on who paid. RR 88-8 held that when a federal employee is billed directly and pays personally (check or credit card) and is later reimbursed, the sale is to the employee and the 7% accommo…
As a coin-operated laundromat, which of my charges are taxable — the wash-and-fold service, vending-machine sales, and cleaning supplies sold by attendants?
It depends on the charge. In Revenue Ruling 88-7 the South Carolina Tax Commission held that (1) 'wash and fold' laundering service is a taxable service under § 12-35-1130(A) — the 1986 phase-out only…
Was fuel used in tugboats exempt from South Carolina sales and use tax when the tugs moved ships, barges, and cargo or assisted ships in Charleston Harbor?
Fuel was exempt when XYZ's tugs generated motive power to transport ships, barges, or cargo. Fuel used only to assist ships in Charleston Harbor was taxable because the ruling did not treat that harbo…
How does South Carolina's accommodations tax apply to a hotel 'golf package' that bundles lodging, greens fees, and a meal for one price?
Break the package into its parts. Revenue Ruling 88-2 held that after a 1987 amendment excluded 'meals and other special items in promotional tourist packages' from the 2% accommodations tax, a hotel …
Were fees paid to cancel noncancelable equipment leases early subject to South Carolina sales and use tax?
Yes. A fee paid to end a noncancelable equipment lease early was part of the lease's gross proceeds and sales price. Calling the payment a cancellation fee did not remove it from South Carolina sales …
Did a South Carolina savings and loan association have to collect sales tax when it sold U.S. Mint Constitution Coins as the Mint's consignee and federal agent?
No. The association sold the Constitution Coins as the U.S. Mint's consignee and agent while the Mint retained ownership, controlled price and recall, and received the proceeds. The sales were immune …
Were a South Carolina motor-vehicle dealer's sales to military non-appropriated fund instrumentalities exempt as sales to the federal government?
Yes. Sales to qualifying non-appropriated fund instrumentalities were treated as sales to the federal government and were exempt from South Carolina sales tax under section 12-35-550(42), effective Ju…
Were tire-shredding machines exempt as processing machinery when they cut discarded tires into pieces before municipal landfill disposal?
No exemption applied. Cutting discarded tires into six segments for landfill disposal was not processing tangible personal property for sale. The Commission treated processing as preparing or converti…
Who was liable for South Carolina's historical tax on bingo proceeds, and could the Commission collect it from a promoter's bond?
The promoter and nonprofit organization were jointly and severally liable, with the promoter primarily liable. The Commission had to assess both and could levy against either party's bond for unpaid t…
Which electricity used at South Carolina apartment complexes was exempt as residential use under Revenue Ruling 92-4?
Electricity for apartments, necessary common areas, and resident-only domestic amenities was exempt. Business areas were exempt only under central metering; separately metered business use and fee-bas…
Under South Carolina's 1989 sales-and-use-tax provisions, were facsimile, database-access, electronic-mail, credit-reporting, and voice-messaging services taxable communications?
Yes. Under the 1989 provisions quoted in the ruling, the listed services were subject to sales and use tax. The Commission treated the transmitted information or message and the means of transmitting …
Did PLR 97-1 require a golf-cart manufacturer to collect sales tax when selling carts and dedicated chargers to golf courses that rented the carts?
No, when the golf course or country club bought the carts for taxable rental to patrons. The cart and its dedicated, included charger were one wholesale sale, and the facility owed tax on the rental f…
When could ZIP Company avoid South Carolina sales or use tax on machinery temporarily stored, repaired, and tested before shipment to a new factory in Mexico?
Tax generally applied unless the property qualified as manufacturing machinery or direct-use equipment, had substantial prior out-of-state use, or fit a statutory storage-for-out-of-state-use exclusio…
Did SC PLR 92-9 exempt the parts and components of a 410-foot power-plant chimney stack as manufacturing pollution-control machinery?
Yes. The ruling classified the described parts, attachments, and components of a 410-foot chimney stack as exempt manufacturing machines. Federal and state agencies had certified the taller stack as n…
Did SC PLR 92-8 exempt a bioabsorbable guided tissue regeneration dental device as a dental prosthetic device?
No. The guided tissue regeneration device helped periodontal tissue or bone regrow and could help prevent tooth loss, but it did not itself replace a missing body part. The ruling therefore did not cl…
How did SC PLR 92-5 apply sales tax and admissions tax to one ticket covering both a four-course meal and a live show?
The ticket was subject to both taxes, but a reasonable, documented allocation could separate the bases: sales tax applied to the meal portion and admissions tax to the entertainment portion. If the op…
Did SC PLR 92-4 exempt prescription-only TENS pain-relief devices from sales and use tax as medicine or prosthetic devices?
No. The ruling treated TENS electrical nerve stimulators sold or leased by ABC Medical as taxable tangible personal property even when prescribed by a physician. They were devices rather than medicine…
Were Westinghouse Savannah River Company's purchases for its federal Savannah River Site contract exempt from South Carolina sales and use tax?
Yes, when Westinghouse Savannah River Company bought tangible personal property on behalf of the federal government under the described Department of Energy contract. The ruling relied on federal titl…
How much South Carolina sales tax is due when a dealer sells a motor vehicle or trailer to an out-of-state resident (per SC IL #13-8)?
When a South Carolina dealer sells a motor vehicle, trailer, semitrailer, or pole trailer to a nonresident who will register and license it in their home state, S.C. Code § 12-36-930 limits the South …
How much South Carolina sales tax is due when a dealer sells a motor vehicle or trailer to an out-of-state resident (per SC IL #13-4)?
When a South Carolina dealer sells a motor vehicle, trailer, semitrailer, or pole trailer to a nonresident who will register and license it in their home state, S.C. Code § 12-36-930 limits the South …
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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.