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Ezel / Tax Rulings / CT
CT Ruling 89-108 Sales and Use Taxes 1989-09-26

How did Connecticut Ruling 89-108 tax landscape design, lawn installation, and site work for residential, new-construction, and commercial property?

Short answer: Landscape-design receipts and the full lawn-installation price were taxable. Separate site work was nontaxable for new construction and qualifying owner-occupied homes but taxable for existing commercial property. DRS says the ruling is partly obsolete.

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, but its page expressly says the information is not current and that AN 2000(8) obsoleted it in part. It is presented as historical reference, not as a complete statement of current landscaping and site-work tax law. 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 treatment.
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 receipts for landscape-design services were taxable. The total sales price for lawn installation was also taxable, including charges for gravel, loam, excavation, and bulldozing.

Site work and excavation for foundations, driveways, and parking lots were not taxable when performed for new construction or existing one-, two-, or three-family property that was exclusively residential and owner-occupied, provided the work was not connected with landscaping.

The same types of site work for existing commercial, industrial, or income-producing property were taxable.

The official page says this information is not current and AN 2000(8) obsoleted the ruling in part.

What this means for you

The historical ruling distinguished taxable landscaping from certain separately performed site work, with property type and use affecting the result. Because DRS marks it partly obsolete, current projects require current guidance.

Common questions

Were landscape-design receipts taxable? Yes.

What was included in the taxable lawn-installation price? Gravel, loam, excavation, and bulldozing charges.

When was foundation, driveway, or parking-lot site work nontaxable? For new construction or qualifying owner-occupied residential property when not connected with landscaping.

Was that site work taxable on existing commercial property? Yes.

Citations and references

  • Conn. Gen. Stat. § 12-407(2)(i)(X), as amended by Public Act No. 89-251, as cited in the ruling.
  • AN 2000(8), identified by the official page as partly obsoleting this ruling.

Source

Original ruling text

Ruling 89-108, Landscaping

This information is not current and is being provided for reference purposes only

This Ruling has been obsoleted in part by AN 2000(8)

The total gross receipts for landscape design services are subject to sales and use tax pursuant to section 12-407(2)(i)(X) of the Connecticut General Statutes, as amended by Public Act No. 89-251. The total sales price for lawn installations is applicable to sales and use tax, inclusive of charges for gravel, loam, excavating and bulldozing services.

Site work and other excavating services rendered to new construction or existing one, two or three family exclusively residential owner-occupied real property for foundations, driveways and parking lots are not taxable provided they are not performed in connection with landscaping services. Site work and other excavating services rendered to existing commercial, industrial, and income-producing real property for foundations, driveways and parking lots are subject to sales and use tax.

LEGAL DIVISION

September 26, 1989

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