Is Utah sales tax owed on dog grooming charges, and how does that compare to veterinary services and animal boarding?

Plain-English summary

This ruling started as an internal question, not a taxpayer request: an American Fork dog groomer applying for a sales tax license asked whether grooming charges were taxable, and a Tax Commission staffer forwarded the question up, noting the groomer had called other dog groomers in Utah County and found only one was collecting sales tax on grooming -- raising a compliance-fairness concern.

The Commission's answer: yes, dog grooming is taxable. The reasoning rests on two building blocks. First, a 1970 Utah Attorney General opinion (No. 70-008) establishes that animals -- specifically including dogs and livestock -- are "tangible personal property" for sales tax purposes, alongside things like wigs and business machines. Second, Utah Admin. Rule R865-19S-78 taxes charges for services that clean tangible personal property. Since grooming a dog is a cleaning service performed on tangible personal property, groomers must collect sales tax on their grooming charges, in addition to any retail products they sell.

The Commission used the opportunity to restate its broader policy on animal-related services, even though the original question only covered grooming:

• Veterinary services are not taxable -- charges for a veterinarian's medical services are exempt. However, sales of medicine, food, and supplies by the vet are taxable (except sales to farmers/agricultural producers using them primarily and directly in farming or agricultural production), and the veterinarian is treated as the consumer -- responsible for tax -- on medicines/supplies used while performing the medical service itself.
• Animal boarding is not taxable. If food is furnished as part of the boarding charge with no separate charge or specific amount stated for it, the boarding business is treated as the consumer of that food (i.e., it's absorbed into the non-taxable boarding service rather than broken out as a taxable sale).

What this means for you

Dog groomers and pet-grooming businesses

Grooming charges are taxable in Utah -- treat them the same as any other service that cleans tangible personal property, and collect sales tax on grooming fees along with any retail pet products you sell.

Veterinary practices

Your medical service charges are not taxable, but you're the "consumer" (and owe use/sales tax) on medicines and supplies you use while treating animals, unless a farm/agricultural exemption applies to that particular sale.

Boarding kennels and pet-boarding businesses

Boarding charges themselves aren't taxable. If you fold food into the boarding fee without a separately stated charge, you (not the customer) are treated as the consumer of that food for tax purposes -- keep that in mind when deciding whether to itemize food charges.

Common questions

Q: Is dog grooming taxable in Utah?
A: Yes -- it's treated as a taxable service to clean tangible personal property (the animal).

Q: Are veterinary medical service charges taxable?
A: No, but the veterinarian generally owes tax as the consumer of medicines and supplies used in treatment (with a farm/agricultural exception).

Q: Is boarding a pet taxable?
A: No, boarding charges are not subject to sales tax.

Q: If a boarding kennel includes food in its rate without itemizing it, does that create a taxable sale of food?
A: No -- the kennel is treated as the consumer of that food, not as making a separate taxable sale to the pet owner.

Q: Can a groomer or vet rely on this ruling if they're audited?
A: This is an internal Commission advisory opinion, not one issued to a specific taxpayer -- it states the Commission's general policy at the time, but any current guidance or audit position should be confirmed directly with the Commission.

Citations and references

Statutes, rules, and opinions cited:

• Utah Admin. Rule R865-19S-78 (charges for services to clean tangible personal property are taxable)
• Utah Attorney General Opinion No. 70-008 (wigs, dogs, livestock, and business machines are tangible personal property)

Source

• Landing page: https://tax.utah.gov/commission/rulings/
• Original PDF: https://files.tax.utah.gov/tax/commission/ruling/95-088.pdf

Original ruling text

95-088

Response December 20, 1995

Request

From: XXXXX

To: XXXXX

Date: 11/24/95 8:49 a.m.

Subject: Dog grooming

Is it possible to send out such a thing as a clarification bulletin?

The reason I ask is a lady in American Fork who applied for a Sales tax license asked if the actual grooming of animals was taxable or considered a service. We contacted XXXXX in auditing and he provided up with R865-19S-78 and referred to Attorney Generals opinion no. 70- 008 dated XXXXX stating wigs, dogs, livestock and a business machine are very clearly within the definition of tangible personal property.

In conveying this to the lady, she claims to have called all listed dog groomers in Utah County and only one charged sales tax on the actual grooming. She is very concerned that if she must collect the sales tax that all of the other groomer be brought into compliance as well, if not she feels she will lose revenue to the shops that do not charge the sales tax.

Would it be possible to send a bulletin to only those in the SIC code of 0752, animal specialty services and 5999 which covers pet food stores and pet shops, those sic codes should cover all who do grooming.

cc: manager

December 20, 1995

XXXXX

Administration Division

Utah State Tax Commission

RE: Advisory Opinion - Application of Sales Tax to Dog Grooming Services

Dear XXXXX,

In response to your request for an advisory opinion regarding the taxability of dog grooming services, we find as follows:

Grooming Services : Dogs and other pets are tangible personal property. Under Utah Administrative Rule R865-19A-78, charges for services to clean personal property are subject to sales tax. Therefore, groomers should be collecting sales tax on charges for grooming services in addition to any sales of retail property that they may make.

Although your request did not address other types of services performed on animals. we will take this opportunity to restate our sales tax policy with regard to some typical types of sales and services related to animals.

Veterinary Services: Charges for medical services performed by a veterinarian are not subject to sales tax. However, sales of medicine, food, and supplies are taxable except sales to farmers and agricultural producers who use the products primarily and directly in farming operations or agricultural production. The veterinarian is considered the consumer of medicines and supplies that he or she uses in the performance of medical services.

Animal Boarding Charges to board an animal are not subject to tax. Where no separate charge or specific amount is charged for food which is furnished as part of the boarding charges. the proprietor is considered the consumer of the food.

The note to you from XXXXX indicates that he received information from one dog groomer concerning widespread non-compliance in the industry. If you receive additional information that supports that claim, please bring it to my attention so we can publish a Tax Bulletin on this topic.

For the Commission,

Alice Shearer