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This Ruling has been superseded in part by Ruling 93-13,
obsoleted  by AN 94(4)

Ruling 89-180


The services that involve providing strategy ideas and design for new products are related to the marketing of products. The gross receipts for the marketing of products are exempt from sales and use tax.

The total sales price for packaging and delivery system designs are subject to sales and use tax as business analysis and management services pursuant to section 12-407(2)(i)(J) of the Connecticut General Statutes, as amended by Public Act No. 89-251.

The services rendered to a large design company a the small design company are subject to sales and use tax unless a valid resale certificate applies. The charge for the design services rendered by the small design company to the large design company located outside Connecticut is not subject to sales and use tax provided the sole benefit and use of the service inure outside Connecticut. A resale certificate may be issued if the large design company resells the designs without altering or modifying them.


October 30, 1989