Are personal and corporate concierge services — like picking up dry cleaning, planning parties, setting up tee times, ordering flowers, or getting car registrations — taxable in Texas?

Plain-English summary

An attorney asked on behalf of a client planning a personal and corporate concierge business — offering services like picking up and dropping off dry cleaning, planning parties, setting up tee times, ordering flowers, and getting car registrations, charging customers a flat fee — whether the service is taxable.

The Comptroller's answer turns on whether the concierge is selling taxable items or purely providing a service:

• Charges to plan parties, set up tee times, or get car registrations are not taxable.
• Pure delivery/transportation is not taxable. If a customer already arranged to buy something (like flowers) and just wants the concierge to pick it up, the concierge should pay for the item (including any tax) and the customer reimburses the concierge for the item, the tax already paid on it, and the concierge's fee.
• Reselling an item changes the picture. If instead the customer doesn't arrange the purchase and the concierge buys the item (like flowers) on the customer's behalf as a genuine sale, the concierge may issue a resale certificate to buy the item tax-free — but then needs a sales and use tax permit and must collect sales tax on both the item and the concierge's own fee.

The letter also flags that Texas taxes certain specifically enumerated "taxable services" separately (referencing Comptroller bulletin 96-259), so a concierge business offering a broader range of services should check whether any particular offering independently falls into one of those taxable service categories.

What this means for you

Concierge and personal-assistant service businesses

Structure your errand-running carefully: if the customer arranges their own purchase and just wants you to pick it up/deliver it, you're providing a nontaxable delivery service — pay any tax on the item yourself and get reimbursed. If you're the one buying the item on the customer's behalf as a mini-retailer, you need a sales tax permit and must collect tax on both the item and your fee (though you can buy the item tax-free for resale). Planning, scheduling, and registration-related services (parties, tee times, car registration) are not taxable regardless of this distinction.

Customers of concierge services

Whether you pay sales tax on the flowers/dry-cleaning/etc. depends on whether you arranged the purchase yourself (concierge just delivers) or had the concierge buy it for you (concierge resells it to you, tax included).

Accountants and tax professionals

The dividing line is delivery-of-a-customer-arranged-purchase (nontaxable) versus concierge-as-reseller (taxable on item + fee). Also remember to separately check any specifically enumerated taxable service categories (per Publication 96-259) that a broad-service concierge business might independently trigger.

Common questions

Q: Is a flat concierge service fee taxable in Texas?
A: Not by itself, if the concierge is only providing transportation/delivery services and planning-type services (parties, tee times, car registration) — those are not taxable.

Q: What if the concierge buys something (like flowers) for the customer instead of just delivering an already-purchased item?
A: Then the concierge is reselling the item and must collect sales tax on both the item and the fee, though the concierge can buy the item tax-free for resale with a permit and resale certificate.

Q: Does getting car registrations for a client trigger sales tax?
A: No. A charge to get car registrations is not taxable.

Q: Can I rely on this letter for my own concierge business?
A: No. This opinion is based on the facts presented; additional or different facts may change the opinion.

Citations and references

No Texas Tax Code section or administrative rule is cited by number in the original letter; it references Comptroller Publication 96-259, "Taxable Services," as a resource for the separately enumerated taxable service categories.

Source

• STAR search: https://star.comptroller.texas.gov/search?doc_type_code=L&tax_type_code=SST
• Opinion: https://star.comptroller.texas.gov/view/200005256L

Original ruling text

May 2, 2000

To: ***, Attorney

Subject: Whether or not service to be provided is subject to sales tax

Dear ***:

I am responding to your e-mail of April 24, 2000 regarding the taxability on a
service your client will provide.

Your client will provide personal and corporate concierge services. The
service will include picking up and dropping off dry cleaning, planning
parties, setting up tee times, ordering flowers, getting car registrations.
The recipient of the services will pay the service provider directly and your
client would collect a flat fee.

A charge for concierge services is not taxable if your client is not selling
taxable items and is merely providing a transportation or delivery service.
For example, if the customer orders some flowers and requests your client's
services to pick up the flowers, then your client should pay for the item
including any tax. Your client's customer will reimburse them for the flowers,
sales tax, and their fee. However, if the customer does not arrange for the
purchase and instead purchases the flowers from your client, then your client
may issue a resale certificate to the seller and purchase the flowers tax free
for resale. If this is the case, your client will need a sales and use tax
permit and must collect sales tax on the flowers and their fee.

A charge to plan parties, set up tee times or get car registrations is not
taxable.

Texas sales and use tax is also imposed on certain services that are taxable
services. See the bulleting "Taxable Services (96-259)" at
www.window.state.tx.us by clicking on "Texas Taxes" and then on "Tax
Publications."

This opinion is based on the facts presented. If there are additional or
different facts, the opinion may change.

If I can be of further assistance, please call me at 1-800-531-5441, extension
5-9913. You may also write to Tax Policy Division, Comptroller of Public
Accounts, P.O. Box 13528, Austin, TX 78711-3825. The e-mail address is
[email protected].

Sincerely,

Elias Amaya
Tax Policy Division