Ezel / Tax Rulings / TX
TX 8606L0740B13 Sales and/or Use Tax (State,Local,MTA) 1986-06-02

How did Texas sales tax apply to replacing a vinyl roof that was a manufactured component of a motor vehicle?

Short answer: A separately billed repair was taxed on parts only. For a lump-sum parts-and-labor charge, the repairer paid tax on the parts and did not charge the customer tax on the repair.

Apply this to your situation

This page answers the general question as of 1986. Ezel answers yours, under current Texas tax law, 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 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 Code Rules 3.1 and 3.10); documents on STAR may no longer represent current policy even if not marked superseded.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

A vinyl roof installed when a vehicle was manufactured was a component part of the motor vehicle under Rule 3.290(a)(2). Repairing that roof was therefore repair of a vehicle component under Rule 3.290(b)(4).

If parts and labor were separately stated, the repairer charged tax on the parts. If the repair was billed as one lump sum without separate parts and labor, the repairer paid tax on the parts and did not charge the customer tax on the repair.

Common questions

Was a factory-type vinyl roof a vehicle component? Yes.

What was taxed on a separated bill? The parts charge.

What happened on a lump-sum bill? The repairer paid tax on the parts and did not charge the customer tax.

Citations and references

  • 34 Tex. Admin. Code Rule 3.290(a)(2) — motor-vehicle component parts.
  • 34 Tex. Admin. Code Rule 3.290(b)(4) — repair of component parts.

Source

Original ruling text

June 2, 1986

Dear ***:

*** has asked me to reply to your request for a decision
on the amount of tax due on the replacement of your vinyl roof.

I understand you had your vinyl roof replaced. When a vehicle is
manufactured with a vinyl roof then the roof is considered a component
part of a motor vehicle (see Rule 3.290 (a)(2)).

The repair of a vinyl roof is the repair of a component part of a motor
vehicle (see Rule 3.290 (b)(4)).

If the repair is billed separated, i.e., parts and labor, then the
repairman should charge tax on the parts.

If the repair is billed lump-sum, i.e., no separately stated amounts for
parts and labor, then the repairman should pay tax on the parts and not
charge his customer tax on the repair.

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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