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Ezel / Tax Rulings / CT
CT Ruling 89-105 Sales and Use Taxes 1989-09-26

Did Connecticut Ruling 89-105 tax landscaping services supplied to a qualifying governmental district?

Short answer: Ordinary landscaping receipts were taxable, but services for an entity qualifying as a district under Conn. Gen. Stat. § 7-324 were exempt when the district gave the landscaper a Governmental Agency Exemption Certificate.

Apply this to your situation

This page answers the general question as of 1989. Ezel answers yours, under current Connecticut tax law, with citations.

Currency note: this ruling is from 1989
Subsequent statutory amendments, regulation changes, court decisions, or later rulings may have changed the analysis. Treat this page as historical context, not current tax advice. Verify current law before relying on any specific rule, rate, or position mentioned here.
Disclaimer: This is an official 1989 Connecticut Department of Revenue Services Ruling applying the law then in effect to landscaping services and qualifying districts. Different entities, missing documentation, or later changes in law or guidance may produce a different result. Connecticut imposes sales and use tax solely at the state level: there are no local or municipal sales taxes. This summary is informational only and is not legal or tax advice. Consult a licensed Connecticut tax professional about current exemption requirements.
About this page: The plain-English summary, reader guidance, and Q&A below were written by Ezel based on the official state tax ruling. The original ruling (linked on this page as a PDF) is the authoritative source for any reliance.
View original ruling (PDF)

Plain-English summary

Total gross receipts for landscaping services were generally subject to sales and use tax.

An exception applied when landscaping was provided to an entity qualifying as a district under Conn. Gen. Stat. § 7-324 and the district furnished the landscaper with a Governmental Agency Exemption Certificate.

What this means for you

The ruling required both a qualifying district and the specified exemption certificate. It did not state that landscaping for every organization or public-facing entity was exempt.

Common questions

Were ordinary landscaping receipts taxable? Yes.

When did the ruling allow an exemption? When the customer qualified as a Section 7-324 district and supplied the Governmental Agency Exemption Certificate.

Did district status alone satisfy the ruling? No. The ruling also required the certificate.

Citations and references

  • Conn. Gen. Stat. § 7-324, as cited in the ruling.

Source

Original ruling text

Ruling 89-105, Landscaping

The total gross receipts for landscaping services are subject to the sales and use tax.

Landscaping services rendered to entities that qualify as districts pursuant to section 7-324 of the Connecticut General Statutes are exempt from sales and use tax provided the district furnishes the landscaper with a Governmental Agency Exemption Certificate.

LEGAL DIVISION

September 26, 1989

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