The total gross receipts for advertising services related to media advertising, inclusive of placement fees and development charges, are not subject to sales and use tax pursuant to section 12-407(2)(i)(W) of the Connecticut General Statutes, as amended by Public Act No. 89-251. The Public Act does not distinguish between the development of ideas or concepts and the development of layouts or mechanicals. The advertising agency is the consumer of all tangible personal property, e.g., graphic designs, artwork, mechanicals, that is purchased for incorporation into media advertising and is liable for payment of the sales or use tax on said purchases.
TIMOTHY F. BANNON
September 28, 1989