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Ezel / Tax Rulings / CT
CT Ruling 90-80 Sales and Use Taxes 1990-12-20

Were basic warehouse storage services subject to Connecticut sales and use tax when no watchman or protective services were provided?

Short answer: No. The company charged a stated price for warehouse storage and provided no watchman or protective service. DRS treated the transaction as rental of storage space rather than rental of tangible personal property, relying on Conn. Agencies Regs. § 12-426-25(f), and held the storage service was not subject to sales and use tax.

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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 Ruling of the Connecticut Department of Revenue Services (DRS), typically issued to a specific taxpayer in response to that taxpayer's request and based on the specific facts presented and the Connecticut tax law in effect when it was issued. DRS may later declare a Ruling obsolete or supersede it by a subsequent Ruling, Policy Statement, or Announcement, so a taxpayer with different facts should not assume it still applies. Taxpayer-identifying details are redacted. Connecticut imposes its 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

A company provided warehouse storage at a stated price and did not add watchman or protective services. DRS held the service was not subject to sales and use tax.

Conn. Agencies Regs. § 12-426-25(f) treated the rental of storage or baggage lockers as rental of storage space, not rental of personal property. The same space-rental treatment applied to the described warehouse storage.

What this means for you

The ruling is narrow: basic storage space without added protective activities. Bundled security or other services could require a different analysis.

Common questions

Was warehouse storage taxable? No on the stated facts.

Why not? DRS classified it as rental of storage space rather than rental of tangible personal property.

Citations and references

  • Conn. Agencies Regs. § 12-426-25(f).

Source

Original ruling text

Ruling 90-80, Storage Services

Ruling 90-80

Storage Services

FACTS:

Company provides warehouse storage services for its customers at a stated price. Company does not perform any activities with respect to such services such as watchman or protective services.

RULING:

Warehouse storage services are not subject to sales and use tax. Section 12-426-25(f) of the Regulation of Connecticut State Agencies provides that "the rental of ... storage or baggage lockers are not rental of personality but rental of storage space and not subject to tax."

LEGAL DIVISION

December 20, 1990

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