Ezel / Tax Rulings / TX
TX 8410L0621E08 Sales and/or Use Tax (State,Local,MTA) 1984-10-31

Was a standalone Texas courier service that delivered documents and small packages for others taxable?

Short answer: No. A business that sold no products and merely delivered documents and small packages provided a nontaxable service. A retailer using that service might still have to tax delivery as part of its own sale.

Apply this to your situation

This page answers the general question as of 1984. Ezel answers yours, under current Texas tax law, with citations.

Currency note: this ruling is from 1984
Subsequent statutory amendments, regulation changes, court decisions, or later rulings may have changed the analysis. Treat this page as historical context, not current tax advice. Verify current law before relying on any specific rule, rate, or position mentioned here.
Disclaimer: This is an official Texas Comptroller of Public Accounts letter published on the State Tax Automated Research (STAR) system. Letters on STAR can be the basis of a detrimental reliance claim only for the taxpayer to whom the letter was directly issued (see 34 Tex. Admin. Code Rules 3.1 and 3.10); documents on STAR may no longer represent current policy even if not marked superseded. Taxpayer-identifying details are redacted. This summary is informational only and is not legal or tax advice. Consult a licensed Texas tax professional about your specific situation.
About this page: The plain-English summary, reader guidance, and Q&A below were written by Ezel based on the official state tax ruling. The original ruling (linked on this page) is the authoritative source for any reliance.

Plain-English summary

The Texas Comptroller said a business that did not sell products and merely delivered documents and small packages for others provided a nontaxable delivery service.

The letter distinguished that standalone service from delivery connected to a retailer's sale. A retailer using the courier might be required to charge tax on the delivery as part of its transaction, even though the courier's service by itself was not taxable.

What this means for you

Couriers and messenger services

Under this letter, a delivery-only business did not collect sales tax on its own service.

Retailers

Hiring a nontaxable courier did not automatically make the retailer's delivery charge nontaxable.

Accountants and tax professionals

Separate the courier's transaction from the retailer's sale and delivery charge. Verify current Texas delivery-charge rules.

Common questions

Q: Was the standalone courier service taxable?
A: No.

Q: Did the courier sell any products?
A: No. The facts said it only delivered documents and small packages for others.

Q: Could a retailer still have to tax delivery?
A: Yes.

Citations and references

  • The letter cites no statute or administrative rule.

Source

Original ruling text

October 31, 1984

Dear **:

Thank you for your recent letter regarding your delivery service. As I
understand it, you do not sell product but merely deliver documents and
small packages for others.

This delivery service is not taxable. A retailer making a sale and using
your service might very well be required to charge tax on the delivery.
However, your service by itself is not taxable.

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

Please feel free to contact us if you have additional questions. You may
call toll free 1-800-252-5555 from anywhere in Texas

Sincerely,

Tax Administration Division

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