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CT Ruling 90-20 Sales and Use Taxes 1990-02-09

Which landscaping, surveying, stakeout, feasibility, engineering, roadway, drainage, and septic-design services were taxable?

Short answer: Under this historical ruling, residential and commercial landscaping, subdivision surveying, and stakeout for real-estate development were taxable. Site feasibility studies, site-development engineering, roadway design, drainage, and septic design were not taxable. DRS later obsoleted the ruling.

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 landscaping, surveying, and design-service rules then in effect. DRS expressly marks it 'not current,' says Announcement (AN) 94(3) obsoleted it in part, and says Announcement (AN) 2000(8) obsoleted it. Its service classifications should not be assumed current or applied to different project scopes. 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," says Announcement (AN) 94(3) obsoleted it in part, and says Announcement (AN) 2000(8) obsoleted it.

Plain-English summary

DRS classified the listed services as follows under the historical rules:

  • Taxable: landscaping for residential or commercial property; land surveying for residential or commercial subdivisions; and stakeout for all real-estate development projects.
  • Not taxable: site feasibility studies, site-development engineering, roadway design, drainage design, and septic design.

What this means for you

The historical ruling separated physical landscaping and development layout from preliminary or infrastructure design. Later announcements obsoleted the guidance, so present classification must be checked independently.

Common questions

Were residential landscaping services exempt? No. The ruling taxed both residential and commercial landscaping.

Was subdivision surveying taxable? Yes, for both residential and commercial property.

Which design services were excluded? The ruling lists feasibility, site-development engineering, roadway, drainage, and septic design.

Citations and references

  • Announcements (AN) 94(3) and 2000(8) -- identified by DRS as obsoleting the ruling.

Source

Original ruling text

Ruling 90-20, Landscaping Services

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

Ruling 90-20

Landscaping Services

This Ruling has been obsoleted in part by  AN 94(3) ; obsoleted by   AN 2000(8)

Landscaping services to both residential and commercial property is subject to tax.

Land surveying services involving the subdividing of both residential and commercial property are subject to tax. Additionally, stakeout of all real estate development projects is taxable.

Site feasibility studies, site development engineering, roadway design, drainage, and septic designs are not subject to tax.

LEGAL DIVISION

February 9, 1990

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