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CT Ruling 89-224 Sales and Use Taxes 1989-11-21

Were environmental engineering services taxable, and how did Connecticut treat building design included with those services?

Short answer: Environmental engineering services were not taxable under this historical ruling, but designing a building to house a facility such as a water-treatment plant was taxable and had to be separately stated. 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. Its distinction between environmental engineering and building design, including separate billing, should not be assumed current. 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 Company X's environmental engineering services were not taxable as building engineering, planning, or design services. The listed work included water and wastewater treatment, solid and hazardous waste, air pollution, water-supply planning, energy, environmental work, laboratory testing, and general consulting.

Designing a building to house a facility such as a water-treatment plant was taxable. The building-design charge had to be separately stated on the client bill.

What this means for you

The historical ruling separated environmental engineering from building design. AN 94(3) later obsoleted the guidance.

Common questions

Were the listed environmental engineering services taxable? No under the ruling.

Was building design taxable? Yes.

How should a taxable building-design charge be billed? Separately stated on the client's bill.

Citations and references

  • Conn. Gen. Stat. § 12-407(2)(i)(F), as cited in the ruling.
  • Announcement (AN) 94(3) -- identified by DRS as obsoleting this ruling.

Source

Original ruling text

Ruling 89-224, Engineering

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

Ruling 89-224

Engineering

This Ruling has been obsoleted by   AN 94(3)

The environmental engineering services rendered by Company X are not subject to the sales and use tax under Conn. Gen. Stat. § 12-407(2)(i)(F) which taxes "building engineering and building planning or design services." These services include water treatment, waste water treatment, solid waste, hazardous waste, air pollution, water supply planning, energy, environmental, laboratory testing and general consulting. If Company X designed a building to house a water treatment plant, for example, such design services are subject to tax and should be separately stated on the bill to the client.

LEGAL DIVISION

November 21, 1989

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