Despite Tuesday's storm, DRS employees are answering emails and phone calls, and completing other essential agency functions. If you have a question about state taxes administered by DRS, email ( or call us (860-297-5962) during regular business hours. Phone wait times are minimal.

Walk-in services at all DRS branch office locations remain suspended.

Email the Priority One Taxpayer Assistance Program:

Please check our Frequently Asked Questions page.

This information is not current and is being provided for reference purposes only

Ruling 89-163


This Ruling has been obsoleted in part by AN 94(10)

You have inquired as to the sales and use tax consequences of the development of software to run equipment. X Company is an engineering and manufacturing company that contracts with independent engineering contractors to develop software to run its equipment. Software discs are the final product received from the engineer. The discs are resold as part of the equipment which cannot operate without them.

The sale of software discs is subject to the sales and use tax under the definition of "sale" and "selling" pursuant to Conn. Gen. Stat. §12-407(2)(c). X Company may purchase the software discs on a resale certificate as long as the following two conditions are met:

1. X Company sells the software discs without change or modification; and

2. X Company retains no proprietary right to the software discs.


October 27, 1989