This Ruling has been modified and superseded by Ruling 2001-3
Electricity - Manufacturing
Utilities - Steam
While a retail sale of electricity or steam may, under certain circumstances, be subject to sales and use taxes, a sale for resale of electricity or steam is not subject to sales and use taxes. See Conn. Gen. Stat. §§ 12-412(3), 12-410 and 12-411. If a sale for resale occurs, the purchaser must issue a resale certificate to the seller.
Purchases of gas for use directly in furnishing steam or electricity delivered to consumers through lines or pipes are exempt from sales and use taxes; Conn. Gen. Stat. §12-412(3); but the applicability of this exemption where electricity is delivered not to consumers, but, instead, to public utilities which are retailers--and not consumers--of electricity, would be contested by this Department.
August 18, 1989