Ruling 90-60

Leasing of Tangible Personal Property
Repair or Maintenance Services

This Ruling has been obsoleted by AN 2000(8)

FACTS:

Section 12-426-25(e) of the Regulations of Connecticut State Agencies allows resale certificates to be issued in the purchase of parts and accessories used directly in the rental or leasing or used in the repair of tangible personal property used exclusively for leasing purposes. Section 12-407(2)(i)(DD) of the General Statutes taxes "any repair or maintenance service to any item of tangible personal property . . ."

ISSUE:

Whether companies in the business of leasing tangible personal property are also permitted to issue resale certificates for the labor portion of repair and maintenance services rendered to their tangible personal property.

RULING:

Resale certificates may be issued when repair and maintenance services are rendered to tangible personal property used exclusively for leasing purposes. The use of resale certificates in this situation is not permitted when the tangible personal property is used by the lessor. This ruling is effective for services rendered on or after September 1, 1990.

In addition, this ruling supersedes Ruling 89-29 so that a leasing company may issue a resale certificate when purchasing painting services rendered to vehicles used exclusively for leasing purposes.

LEGAL DIVISION

August 10, 1990