Connecticut State Department of Revenue Services

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Ruling 90-29

Architectural Services

This Ruling has been obsoleted by AN 94(3)

You have inquired whether the sales tax on architectural services applies to the following proposed transaction.

A Connecticut corporation owned equally by four individuals (A, B, C & D) is licensed to provide architectural services. This corporation is entering into architectural contracts with the State of Connecticut and expects to subcontract some or, in some cases, all of the architectural work to a foreign corporation owned by A, B, and C.

It is ruled that architectural services rendered to the State of Connecticut, either directly or indirectly pursuant to a subcontract are exempt from the sales tax. The Connecticut corporation may issue a resale certificate to the foreign corporation with respect to work performed by the foreign corporation. Thus, the architectural services sold to the State of Connecticut by the Connecticut corporation are exempt from the sales tax.

LEGAL DIVISION

February 26, 1990