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Ezel / Tax Rulings / CT
CT Ruling 89-138 Sales Tax 1989-10-10

Were all receipts from Company X's valet parking service subject to Connecticut sales tax?

Short answer: Yes. The total receipts were taxable because valet parking included all aspects of the parking service, including providing spaces, and the company could not break out a separate valet component. DRS says AN 94(3) partly obsoleted and AN 2000(8) obsoleted the ruling.

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 reflecting the sales-tax treatment of the described valet parking receipts then in effect. DRS expressly marks the information 'not current,' says Announcement (AN) 94(3) obsoleted it in part, and says AN 2000(8) obsoleted it. The ruling does not identify which conclusion AN 94(3) changed. Connecticut imposes sales 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)

Note -- obsolete historical guidance. DRS marks this information "not current," states that Announcement (AN) 94(3) obsoleted it in part, and states that AN 2000(8) obsoleted it.

Plain-English summary

Company X provided valet parking. DRS concluded that the service's total receipts were subject to sales tax.

The company could not separate an amount allocated to a so-called valet component. The ruling treated valet parking as including all aspects of the parking service, including providing parking spaces.

What this means for you

The historical ruling treated the described valet parking charge as one taxable parking service rather than a separately stated valet component. Later DRS announcements obsoleted the guidance.

Common questions

Were total valet parking receipts taxable? Yes.

Could the company break out a separate valet component? No under the stated arrangement.

What did valet parking include? All aspects of the parking service, including providing spaces.

Citations and references

  • Announcement (AN) 94(3) -- identified by DRS as partly obsoleting this ruling.
  • Announcement (AN) 2000(8) -- identified by DRS as obsoleting this ruling.

Source

Original ruling text

Ruling 89-138, Parking

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

This Ruling has been obsoleted in part by AN 94(3) ;  obsoleted by AN 2000(8)

Company X provides a valet parking service. The total receipts of valet parking services are subject to sales tax. They are not able to break out that portion which they have allocated to a so-called valet component. Valet parking includes all aspects of the parking service including but not limited to providing spaces.

TIMOTHY F. BANNON

COMMISSIONER

October 10, 1989

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