Ezel / Tax Rulings / TX

How did Texas tax vehicle window-tinting charges before and after the February 12, 1986 rule change?

Short answer Before February 12, film and installation were taxable unless labor was separately stated; afterward, lump-sum jobs were nontaxable and separated materials taxable.
State
TX
Ruling
8602L0694E13
Tax type
Sales and/or Use Tax (State,Local,MTA)
Issued
1986-02-03
Issued by
Texas Comptroller of Public Accounts, Tax Policy Division
Requested by
A business applying solar film to automobile and truck windows (identity redacted)
Topics
sales tax motor vehicles window tinting lump sum contracts separated contracts installation labor

Apply this to your situation

This page answers the general question as of 1986. Ask about yours and see what current Texas tax law says, with citations.

Currency note: this ruling is from 1986
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 1986 Texas Comptroller taxpayer-response letter describing a time-specific change effective February 12, 1986. It distinguishes lump-sum from separated contracts and expressly says different facts could change the opinion. Do not treat its historical effective-date rules as current law without verification. STAR documents may no longer represent current policy even when not marked superseded, and letters on STAR can support detrimental reliance only for the taxpayer to whom the letter was directly issued under 34 Tex. Admin. Code Rules 3.1 and 3.10. Taxpayer-identifying details are redacted. This summary is informational only and is not legal or tax advice.
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

At the time of the February 3 letter, applying solar film to an automobile or truck was treated as selling and installing tangible personal property. The business had to collect sales tax on the film's selling price. Installation was also taxable unless separately stated to the customer.

The letter announced a different treatment effective February 12, 1986, when installing solar film would be considered motor-vehicle maintenance. Under a lump-sum contract, the business would not collect tax from the customer but would pay tax when buying the materials. Under a separated contract, it would collect tax on the materials' selling price, while labor would be nontaxable.

Common questions

Was installation labor taxable before February 12, 1986? Yes, unless separately stated.

How was a lump-sum tinting contract treated after the change? The business did not collect tax on the lump sum and instead paid tax on the materials it purchased.

How was a separated contract treated? The business collected tax on the selling price of materials, while labor was nontaxable.

Citations and references

The reproduced letter cites no numbered statute or rule.

Source

Original ruling text

February 3, 1986

Dear ***:

Thank you for your letter of January 23, 1986 concerning the taxability of solar film applied to the windows of automobiles and trucks.

At the present time, applying solar film to a vehicle is considered a sale and installation of tangible personal property. You must collect sales tax from your customer based on the selling price of the film. The installation charge is also subject to sales tax, unless you separately state the installation charge to your customer.

Effective February 12, 1986, installing solar film will be considered maintenance of a motor vehicle. If you operate under lump sum contracts with your customers, you will not collect sales tax on the lump sum charge. You will pay sales tax on the materials used to perform the contract at the time you purchase them from your supplier.

If you operate under a separated contract, you must collect sales tax from your customer based on the selling price of the materials. The labor is not taxable.

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

If you have any questions or need more information, please call us at 1-800-252-5555 toll free from anywhere in Texas. You may write us at the Tax Administration Division.

Sincerely,

Tax Policy Section
Tax Administration Division

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