Ezel / Tax Rulings / TX
TX 9609L1435G14 Motor Vehicle Tax 1996-09-09

Were separately stated delivery and tank-cleaning charges subject to Texas motor vehicle rental tax?

Short answer: No. The Tax Policy Division said separately stated cleaning and delivery charges were not subject to motor vehicle rental tax. The letter attributed that treatment to a recent motor vehicle administrative hearing but did not identify the decision.

Apply this to your situation

This page answers the general question as of 1996. Ezel answers yours, under current Texas tax law, with citations.

Currency note: this ruling is from 1996
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 Tax Policy letter issued on one 1996 rental-charge question. It predates modern Private Letter Ruling reliance terms and cannot be treated by unrelated taxpayers as binding protection. The letter relies on an unidentified administrative hearing, and current rental-tax treatment, separate-statement requirements, and taxable-charge definitions may differ. 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

The Texas Tax Policy Division said separately stated charges for cleaning or delivering a rented motor vehicle were not subject to motor vehicle rental tax.

The request specifically concerned delivery and tank-washout charges. The letter said a recent motor vehicle administrative hearing had established the treatment but did not name or cite that hearing.

What this means for you

Vehicle and tanker rental companies

Separate statement was an express condition of the historical result.

Rental fleet accountants

The letter treated the rental charge differently from separately stated delivery and cleaning charges.

Common questions

Q: Were the separately stated delivery charges taxable?

A: No, under the treatment described.

Q: Were separately stated tank-washout charges taxable?

A: No.

Citations and references

  • The letter referred to a recent motor vehicle administrative hearing without identifying it.

Source

Original ruling text

September 9, 1996

Dear ***:

Thank you for your letter concerning motor vehicle rental tax being charged
on delivery and tank washout charges.

Separately states charges for cleaning or delivery are not subject to motor
vehicle rental tax. This was established by a recent motor vehicle
administrative hearing.

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

If you have any questions, please don't hesitate to write the Tax Policy
Division or call one of our Tax Specialist at 1-800-252-1382, toll free.

Sincerely,

Curt Swenson
Tax Policy Division

NOTE: Previous Accession Number 9609648L

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