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Ezel / Tax Rulings / CT
CT Ruling 89-65 Sales and Use Taxes 1989-08-22

How did Connecticut Ruling 89-65 tax marketing research and related consulting services?

Short answer: Marketing research was exempt, but advice to businesses about the research findings or results was taxable consulting. If exempt research and taxable consulting were not separately stated on the invoice, the ruling applied tax to the total sales price. The ruling is obsolete.

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 1989 Connecticut Department of Revenue Services Ruling is not current. The official page says it was obsoleted by Announcement 94(4), so it is provided only as historical reference and should not be used as current authority. It addressed marketing research, related consulting, and invoice presentation under the law then in effect. 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 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)

Plain-English summary

Marketing research services were exempt from sales and use tax, but consulting services provided to businesses were taxable under this ruling.

The dividing line was advice: if the provider advised a business about its marketing research findings or results, the charge for that consulting service was taxable. If the exempt research and taxable consulting were combined rather than separately stated on the invoice, tax applied to the total sales price.

The official archive says this ruling was obsoleted by Announcement 94(4).

What this means for you

The historical ruling treated research and advice as different services and made separate invoice presentation important. Because it is expressly obsolete, current service classifications and bundling rules must be checked separately.

Common questions

Was marketing research taxable? No, under this ruling.

When did the service become taxable consulting? When the provider advised businesses about the marketing research findings or results.

What if the charges were combined? The ruling applied tax to the total sales price when research and consulting were not separately stated.

Citations and references

  • Conn. Gen. Stat. § 12-407(2)(i)(J), as cited in the ruling.
  • Public Act No. 89-251, as cited in the ruling.

Source

Original ruling text

Ruling 89-65, Marketing

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

Ruling 89-65

Marketing

This Ruling has been obsoleted by  AN 94(4)

Marketing research services are exempt from sales and use tax.

Consultation services rendered to businesses are subject to sales or use tax pursuant to section 12-407(2)(i)(J) of the Connecticut General Statutes, as amended by Public Act No. 89-251. If you render advice to businesses concerning your marketing research findings or results, then you must apply sales tax to your charges for consulting services. In the event that the marketing research and consulting services are not separately stated on the invoice, then the total sales price is applicable to the tax.

LEGAL DIVISION

August 22, 1989

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