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Ruling 91-18

Sales and Use Taxes Advertising Services

This Ruling has been cited in Ruling 93-8

ISSUE:

Does the term "media advertising", as used in Conn. Gen. Stat. §12-407(2)(i)(W), include advertisements placed on the sides of trailer-trucks?

FACTS:

Company charges for the placement of advertisements on the sides of its trailer trucks.

DISCUSSION:

The rendering of advertising services "not related to the development of media advertising" constitutes a "sale" or "selling"; Conn. Gen. Stat. §12-407(2)(i)(W). "Media advertising means advertisements in newspapers and magazines and on radio, television and cable television stations. Media advertising also includes advertisements placed on billboards, buses or taxicabs." TSSN-30 (NEW 6-90). The term "media advertising" is intended to encompass advertisements placed in a medium that has as its audience the public at large. The placement of advertisements on the sides of trailer-trucks that are used on, or stationed along, public thoroughfares will not be treated differently than the placement of advertisements on buses, trains and taxicabs.

RULING:

The term "media advertising", as used in Conn. Gen. Stat. §12-407(2)(i)(W), includes advertisements placed on the sides of trailer-trucks that are either used on, or stationed in public view along, public thoroughfares, and charges related to the development of such advertising are not subject to sales and use taxes.

LEGAL DIVISION

MAY 16, 1991