This Ruling has been obsoleted by PS 94(2)
You have requested clarification on whether one who repairs an appliance under a manufacturer's warranty and subsequently charges the manufacturer for such labor performed must charge the manufacturer for sales tax on the cost of these repair services.
Prior to July 1, 1989, when repair and maintenance services to tangible personal property were not enumerated services, labor supplied by authorized representatives other than the warrantor, was not subject to sales and use tax. Where a warrantor's (e.g., manufacturer) authorized dealer used a third party in effecting the repair, the third party had to charge tax on the parts to the dealer, who, in turn, could be reimbursed by the warrantor.
Pursuant to section 12-407(2)(i)(DD) of the Connecticut General Statutes, repair and maintenance services performed on or after July 1, 1989 to any item of tangible personal property (which includes appliances) are subject to tax.
July 10, 1989
Note: The remainder of this ruling has been superseded by Commissioner Timothy F. Bannon's letter of November 16, 1989 on manufacturer's warranty and extended warranty. Please refer to Ruling 89-152.