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Ezel / Tax Rulings / CT
CT Ruling 89-188 Sales and Use Taxes 1989-10-31

Were industrial wastewater-treatment and metal-finishing process-system design services subject to Connecticut sales and use tax?

Short answer: No under this historical ruling. DRS said the two listed process-system design services and the source letter's unspecified non-design efforts were not taxable under the building-engineering provision. DRS says AN 94(3) 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 engineering-service rules then in effect. DRS expressly marks the information 'not current' and says Announcement (AN) 94(3) obsoleted it. The published text does not describe the letter's 'non-design efforts,' so no broader conclusion should be inferred beyond the two named process-system designs. 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 your specific situation.
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" and states that Announcement (AN) 94(3) obsoleted the ruling.

Plain-English summary

DRS said design of industrial wastewater-treatment systems and metal-finishing process systems was not subject to sales and use tax under the cited building-engineering provision.

It gave the same result for unspecified "non-design efforts" described in the request letter, but those facts are absent from the published ruling.

What this means for you

The historical ruling supports only the two named design categories. AN 94(3) later obsoleted the guidance.

Common questions

Was industrial wastewater-treatment system design taxable? No under the ruling.

Was metal-finishing process-system design taxable? No.

What were the nontaxable non-design efforts? The published text does not say.

Citations and references

  • Conn. Gen. Stat. § 12-407(2)(i)(F), as cited in the ruling.
  • Public Act No. 89-251, as cited in the ruling.
  • Announcement (AN) 94(3) -- identified by DRS as obsoleting this ruling.

Source

Original ruling text

Ruling 89-188, Engineering

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

Ruling 89-188

Engineering

This Ruling has been obsoleted by   AN 94(3)

The design of industrial wastewater treatment systems, the design of metal finishing process systems, and the non-design effects outlined in your letter are not subject to the Connecticut sales and use tax under section 12-407(2)(i)(F), of the Connecticut General Statutes, as amended by Public Act No. 89-251.

LEGAL DIVISION

October 31, 1989

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