Ezel / Tax Rulings / TX
TX 8711L0846B11 Sales and/or Use Tax (State,Local,MTA) 1987-11-03

How did Texas sales tax apply to snapshots supplied while performing services for insurance companies, including the film and developing charges?

Short answer: The provider's total charge to the insurance-company client for snapshots and services was taxable. The provider paid tax when buying film but could issue a resale certificate instead of paying tax on film developing.

Apply this to your situation

This page answers the general question as of 1987. Ezel answers yours, under current Texas tax law, with citations.

Currency note: this ruling is from 1987
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 a taxpayer-specific November 1987 Texas Comptroller letter about snapshots and related services provided to insurance-company clients. It says the opinion may change if the facts differ. Its October 1, 1987 insurance-service rule, film-purchase treatment, developing-service resale treatment, and total-charge conclusion are historical and may have changed substantially; verify current Rule 3.555 and the full service contract. STAR documents may no longer represent current policy even when not marked superseded. Identities 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

The total charge to the insurance-company client for snapshots and services was taxable.

The provider had to pay sales tax when buying the film. But it could issue a resale certificate instead of paying tax on developing the film.

The letter said Rule 3.555 outlined the insurance services taxable as of October 1, 1987.

What this means for you

The historical letter separated the provider's inputs: film was a taxable purchase by the provider, while developing could be bought for resale. The provider still taxed its total charge to the client for the snapshots and services.

Common questions

Was only the snapshot charge taxable? No. The total charge for the snapshots and services was taxable.

Did the provider pay tax on film? Yes, at the time of purchase.

Could the provider give a resale certificate for developing? Yes.

Citations and references

  • 34 Tex. Admin. Code Rule 3.555 (insurance services)

Source

Original ruling text

COMPTROLLER OF PUBLIC ACCOUNTS
STATE OF TEXAS
AUSTIN, 78774

November 3, 1987

Dear ***:

Thank you for your letter regarding taxability of work performed for
insurance companies.

I am enclosing Rule 3.555 which outlines the insurance services that are
taxable as of October 1, 1987.

You specifically asked about sales tax on an invoice for snapshots. The
total charge to your client for the snapshots and services is taxable.
The
film is taxable to you at the time of purchase. A resale certificate can
be
issued in lieu of the tax on the developing of the film.

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 me at
1-800-252-5555 toll free form anywhere in Texas. The regular number is
512/463-4600. You may write me at the Tax Policy Division.

Sincerely,
(Mrs.) Jo Ann Dieck
Tax Policy Division

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