This Ruling has been superseded by PS 92(13)
Company X is engaged in the business of providing television studios, editing rooms and other post production facilities to its clients who use the facilities for producing finished television programs for broadcast purposes.
Section 12-412(44) of the Connecticut General Statutes states:
Taxes imposed by this chapter shall not apply to the gross receipts from the sale of and the storage, use or other consumption in this state with respect to the following items . . . Sales of and the storage, use or other consumption of any materials or equipment which become an ingredient or component part or which are used directly in the production and transmission of finished programs broadcast to the general public by a television or radio station.
The exemption provided under section 12-412(44) applies exclusively to television or radio stations. Company X does not fall within the purview of section 12-412(44) and must pay sales or use tax for purchases of materials and/or equipment used in its facilities.
The charge to your clients for use of the facilities, including equipment contained therein, is not subject to sales or use tax.
August 15, 1989