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Ezel / Tax Rulings / CT
CT Ruling 89-264 Sales and Use Taxes 1989-12-07

When were plumbing, HVAC, appliance installation, and repair labor taxable for owner-occupied homes and business property?

Short answer: Installation labor was nontaxable at new construction and qualifying owner-occupied one- to three-family homes but taxable on existing commercial, industrial, or income-producing property. Repairs to listed equipment such as HVAC units, water heaters, disposals, and dishwashers were taxable everywhere. Repairs to sinks, toilets, bathtubs, and standalone pipes followed the residential-versus-business property split.

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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 installation and repair rules then in effect to specified plumbing, HVAC, and appliance work. The result depended on property type and whether work was installation, equipment repair, or plumbing repair; later legal changes or different facts can change the answer, so another contractor should not assume it applies. 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)

Plain-English summary

The ruling separated installation labor, equipment repair, and plumbing repair.

Installation labor for air-conditioning, water, heating, ventilation, and exhaust systems, plus sinks, toilets, bathtubs, dishwashers, and garbage disposals, was not taxable at new construction or existing one-, two-, or three-family property that was exclusively residential and owner-occupied. The same installation work was taxable at existing commercial, industrial, or income-producing property.

Repairs to equipment such as air-conditioning units, furnaces, oil burners, heat pumps, water heaters, water pumps, water conditioners, water coolers, exhaust fans, garbage disposals, and dishwashers were taxable in both residential and commercial realty.

Repairs to sinks, toilets, bathtubs, and pipes not part of those units were treated as plumbing services to real property. They were nontaxable at qualifying owner-occupied homes but taxable at existing commercial, industrial, or income-producing property.

What this means for you

The historical result required classifying both the property and the work. Equipment repair stayed taxable across property types, while installation and standalone plumbing repair followed the residential/business property distinction.

Common questions

Was HVAC installation at a qualifying owner-occupied home taxable? No under the ruling.

Was furnace repair taxable at that same home? Yes.

Were sink and pipe repairs taxable at business property? Yes.

Citations and references

  • The published ruling cites no specific statute or regulation.

Source

Original ruling text

Ruling 89-264, Installation/Repairs

The labor charges by plumbing, heating and cooling contractors for installations of air conditioning, water, heating, ventilation and exhaust systems, as well as sinks, toilets, bathtubs, dishwashers and garbage disposals provided to new construction or existing one, two or three family exclusively residential owner-occupied homes are not taxable. Labor charges by contractors for installations of air conditioning, water, heating, ventilation and exhaust systems as well as sinks, toilets, bathtubs, dishwashers and garbage disposals rendered to existing commercial, industrial or income-producing real property are subject to sales and use tax. Repairs to items such as air conditioning units, furnaces, oil burners, heat pumps, water heaters, water pumps, water conditioners, water coolers, exhaust fans, garbage disposals and dishwashers performed in residential or commercial realty are subject to sales and use tax.

Repairs to sinks, toilets, bathtubs and pipes which are not part of the units stated above are considered to be plumbing services to real property and are not taxable when rendered to existing one, two or three family exclusively residential owner-occupied homes. However, the repairs are taxable when provided to existing commercial, industrial or income-producing property.

LEGAL DIVISION

December 7, 1989

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