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Ezel / Tax Rulings / CT
CT Ruling 90-11 Sales and Use Taxes 1990-01-31

Was sharpening or resharpening cutting tools used in manufacturing taxable, and could the manufacturer issue an exemption certificate?

Short answer: Under this historical ruling, sharpening manufacturing cutting tools was a taxable repair or maintenance service. The manufacturer could not issue a resale certificate or manufacturer's exemption certificate to the sharpening provider. DRS marks the ruling not current and obsoleted by AN 2000(8).

Apply this to your situation

This page answers the general question as of 1990. Ezel answers yours, under current Connecticut tax law, with citations.

Currency note: this ruling is from 1990
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 1990 Connecticut Department of Revenue Services Ruling reflecting the tool-repair and exemption-certificate rules then in effect. DRS expressly marks it 'not current' and says Announcement (AN) 2000(8) obsoleted it. Its sharpening classification and certificate restriction should not be assumed current or applied to different manufacturing 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

DRS classified sharpening or resharpening cutting tools used in a manufacturing production process as a taxable repair or maintenance service.

Manufacturers could not issue resale certificates or manufacturer's exemption certificates to the business providing the sharpening service.

What this means for you

Under the historical ruling, a tool's use in production did not exempt the service that restored its cutting edge. The service provider had to treat sharpening as taxable rather than accept the listed certificates.

Common questions

Did manufacturing use exempt the sharpening? No.

Could the manufacturer issue a resale certificate? No.

Could it use a manufacturer's exemption certificate? No.

Citations and references

  • Conn. Gen. Stat. § 12-407(2)(i)(DD), as amended by 1989 Conn. Pub. Acts 251.
  • Announcement (AN) 2000(8) -- identified by DRS as obsoleting this ruling.

Source

Original ruling text

Ruling 90-11, Repair and Maintenance

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

Ruling 90-11

Repair and Maintenance

This Ruling has been obsoleted by   AN 2000(8)

The sharpening or resharpening of cutting tools used in a manufacturing production process is a taxable repair or maintenance service pursuant to Section § 12-407(2)(i)(DD) as amended by Public Act 89-251. Resale certificates or manufacturers exemption certificates cannot be issued to a producer of sharpening services by manufacturers whose cutting tools are sharpened or resharpened.

LEGAL DIVISION

January 31, 1990

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