Connecticut State Department of Revenue Services

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Ruling 89-247, Personnel Services

Model usage fees are subject to sales tax as an employment service. The agency using models is required to pay the sales tax on the model agency's fee. The advertising agency is the ultimate consumer of the model agency's services. As the ultimate consumer, it must pay the tax on such service and cannot issue a resale certificate.

TIMOTHY F. BANNON
COMMISSIONER

November 29, 1989