Is translating documents (assembly instructions, labels, tags, price lists, and legal documents) from English to Spanish a taxable service in Texas?

Plain-English summary

A taxpayer faxed the Comptroller's office asking whether its services translating assembly instructions, labels, tags, price lists, and legal documents from English to Spanish are taxable. The Tax Administration Division responded that the translation services are not taxable, either to in-state or out-of-state customers. The letter notes that the opinion is based on the facts presented and could change if additional or different facts were involved.

What this means for you

Businesses offering translation services

If your business translates documents — such as assembly instructions, labels, tags, price lists, or legal documents — from one language to another, this letter indicates that the Comptroller does not treat that service as taxable, regardless of whether the customer is located in Texas or out of state.

Businesses that purchase translation services

Because the letter found translation services not taxable, a business paying for document translation (of the kind described here) would not be charged sales tax on that service under this ruling.

Accountants and tax professionals

This is a short, fact-based letter addressing a specific set of translation services (assembly instructions, labels, tags, price lists, and legal documents translated from English to Spanish). The letter does not cite any statute or rule, and it expressly states the opinion is based on the facts presented and may change if the facts differ.

Common questions

Q: Does it matter whether the customer is in Texas or out of state?
A: No. The letter states the translation services are not taxable to in-state or out-of-state customers.

Q: What kinds of documents were covered by this ruling?
A: The taxpayer asked about translating assembly instructions, labels, tags, price lists, and legal documents from English to Spanish.

Q: Can other taxpayers rely on this letter?
A: This is a fact-specific letter ruling addressed to a particular taxpayer, and the letter itself notes the opinion could change with different facts. STAR letters generally may be relied on as the basis of a detrimental reliance claim only by the taxpayer to whom they were issued.

Citations and references

No specific statutes or administrative rules are cited in the text of this letter.

Source

• STAR search: https://star.comptroller.texas.gov/search?doc_type_code=L&tax_type_code=SST
• Opinion: https://star.comptroller.texas.gov/view/9502L1337A08

Original ruling text

February 17, 1995

Dear **:

I received the fax you sent on February 9, 1995. You asked whether your
services to translate assembly instructions, labels, tags, price list and legal
documents from English to Spanish are taxable.

Your translation services are not taxable to in-state or out-of-state
customers.

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

You may call me toll free at 1-800-531-5441, ext. 5-0037. The direct line is
512/475-0037. You also may write to Tax Administration Division, Comptroller of
Public Accounts.

Sincerely,

Lindey Osborne
Tax Administration Division