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Ezel / Tax Rulings / CT
CT Ruling 89-270 Sales and Use Taxes 1989-12-11

Were manufacturing tool-resharpening services taxable when performed inside or outside Connecticut?

Short answer: Yes under this historical ruling. Beginning July 1, 1989, repair and maintenance services to tangible personal property were taxable, including tool sharpening obtained by Connecticut companies even when performed outside the state. DRS said manufacturing use created no repair-service exemption. The ruling is not current and was obsoleted by AN 2000(8).

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 repair-service rules effective July 1, 1989. DRS expressly marks it 'not current' and says Announcement (AN) 2000(8) obsoleted it. Its manufacturing and out-of-state sharpening treatment should not be assumed current or applied to different repair services. 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 ruling "not current" and states that it was obsoleted by Announcement (AN) 2000(8).

Plain-English summary

As of July 1, 1989, Connecticut taxed repair and maintenance services to tangible personal property.

DRS applied that rule to resharpening tools used to manufacture products. Connecticut companies owed tax on tool-sharpening services whether the work was performed in Connecticut or elsewhere.

Manufacturing use did not create an exemption for the repair or maintenance service.

What this means for you

The historical ruling treated out-of-state performance as irrelevant when a Connecticut company obtained the tool service. It also rejected an implied manufacturing exemption that the Legislature had not enacted.

Common questions

Was tool sharpening a taxable repair service? Yes.

Did out-of-state sharpening avoid Connecticut tax? No under the ruling.

Did manufacturing use create an exemption? No.

Citations and references

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

Source

Original ruling text

Ruling 89-270, Repair Services

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

Ruling 89-270

Repair Services

This Ruling has been obsoleted by   AN 2000(8)

This is in reply to your recent letter concerning the resharpening of tools used to manufacture products.

As of July 1, 1989, repair and maintenance services to tangible personal property are subject to sales and use tax. This tax applies to all Connecticut companies obtaining a tool sharpening service whether or not such service is performed in Connecticut.

There is no provision in our tax law to exempt from tax repair or maintenance service used in manufacturing. This Department is bound to interpret the tax laws as written by the Legislature and must look to the Legislature for specific exemptions should they apply.

TIMOTHY F. BANNON

COMMISSIONER

December 11, 1989

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