Does a campground owe sales tax on cabin, tent, and RV site rentals to guests who stay 30 days or more?

Plain-English summary

The Missouri Department of Revenue ruled on a campground operator's two long-term lodging questions, reaching different answers for cabins versus campsites/RV sites: cabin stays of 30 days or more are exempt, but campsite and RV site stays of 30 days or more are not.

Missouri regulation 12 CSR 10-110.220 exempts lodging rented to "permanent residents" -- individuals who contract in advance for a room for 30 consecutive days or more and actually stay that long, and who aren't renting as a business. The Department treated the campground's cabins as similar to hotel or motel rooms under this regulation, so individual non-business guests who contract for and actually occupy a cabin for 30+ days qualify as permanent residents and their cabin fees are exempt. But camping sites and RV sites are not "rooms," so the same 30-day permanent-resident exemption doesn't extend to them -- those rentals stay taxable no matter how long the guest stays.

What this means for you

Campground and RV park operators

Don't assume that a long-term stay automatically becomes tax-exempt across your whole property. The permanent-resident lodging exemption in 12 CSR 10-110.220 applies to enclosed lodging units comparable to hotel/motel rooms -- cabins qualify, but bare camping sites and RV pads do not, even for guests who contract in advance and stay 30 days or longer.

RV park and campsite-only operators

If your business rents only tent sites or RV pads (no cabins or similar enclosed rooms), this ruling indicates you should keep collecting sales tax on all site rentals regardless of length of stay -- the 30-day permanent-resident exemption doesn't apply to non-room sites.

Accountants and tax professionals serving hospitality/recreation clients

When applying the permanent-resident lodging exemption, check whether the specific unit being rented is a "room" (cabins, hotel/motel-style units) versus a bare site (tent pad, RV pad) -- this ruling shows the Department draws that line strictly, exempting one and taxing the other under otherwise-identical 30-day-stay facts.

Common questions

Q: Does staying 30+ days at a campground ever make my rental tax-free?
A: Only if you're renting a cabin (or similar enclosed room) as an individual, non-business guest who contracts in advance and actually stays 30 consecutive days or more. Tent camping sites and RV sites don't qualify for this exemption regardless of stay length.

Q: Why are cabins treated differently from RV and camping sites?
A: The exemption in 12 CSR 10-110.220 is written for "rooms," and the Department found cabins comparable to hotel and motel rooms. Camping sites and RV sites are physical land plots, not rooms, so the regulation's exemption doesn't reach them.

Q: Does the campground still owe tax on canoe rentals, snacks, and supplies?
A: This ruling doesn't change how those sales are taxed -- it only addresses long-term lodging. The facts note the campground already charges sales tax on daily camping, snacks, refreshments, and supplies, and pays sales tax itself when buying canoes for rental.

Q: Can another campground operator rely on this ruling for its own long-term site rentals?
A: No. A Missouri letter ruling binds the Department only as to the requesting Applicant, only for three years, and only while the facts and law don't change. Another operator should confirm its own lodging types against 12 CSR 10-110.220 or consult a tax professional.

Citations and references

Regulations:

• 12 CSR 10-110.220 (exemption from sales tax for lodging rented to permanent residents)

Source

• Landing page: Missouri DOR Rulings Search
• Ruling: LR 8351

Original ruling text

Dear Mr. Applicant:

This is a letter ruling issued by the Director of Revenue under Section 536.021.10, RSMo, and Missouri Code of State Regulations 12 CSR 10-1.020, in response to your letter dated March 12, 2025.

The facts as presented in your letter ruling request are summarized as follows:

Applicant operates a campground and rents canoes to the public in Missouri.   Applicant charges sales tax on short-term daily tent camping, at RV sites, and at cabins.   Applicant also collects sales tax on sales of snacks, refreshments, and camping supplies.   Applicant pays sales tax to vendors when it purchases canoes for rental to customers.

ISSUE 1:

Should Applicant charge sales tax to individual non-business customers who contract in advance and occupy cabins for more than thirty days ?

RESPONSE 1:

No.   Sales tax is not due on rentals to individual non-business customers who contract in advance and occupy cabins for more than thirty days.   Permanent residents are those who contract to rent lodging for thirty consecutive days or more and actually stay that time.

Although lodging is generally treated as subject to sales tax, 12 CSR 10-110.220 creates an exemption for lodging of permanent residents.   A permanent resident is “an individual who contracts in advance for a room for a period of thirty consecutive days or more and who actually remains a guest for thirty consecutive days or more” and is not a business.   The cabins offered by Applicant are similar to hotels and motels under 12 CSR 10-110.220 because they provide rooms to customers. Applicant’s customers are permanent residents because they contract for and actually stay for thirty days or more and are not businesses.   As permanent residents they are not subject to sales tax.

ISSUE 2:

Should Applicant charge sales tax to individual non-business customers who contract in advance and occupy camping sites and RV sites for more than thirty days ?

RESPONSE 2:

Yes. Applicant should   charge sales tax to individual non-business customers who contract in advance and occupy camping sites and RV sites for more than thirty days.

The exemption discussed in Response 1 applies to rooms that are rented to individuals who contract and stay in a room for more than 30 days.   Camping sites and RV sites are not rooms, so the exemption in 12 CSR 10-110.220 does not apply.   Therefore, Applicant should collect sales tax on the rentals of camping sites and RV sites, even if contracted in advance for more than 30 days.

This letter ruling is binding upon the Department of Revenue with respect to the Applicant for three (3) years from the date of this letter and is subject only to statutory changes by the General Assembly and to changes in the interpretation of law by the courts or administrative tribunals.   If a change occurs, the taxpayer who relies upon an outdated interpretation may be subject to additional taxes, interest and penalties, which may be imposed prospectively from the date of the change.   For this reason, the interpretation set forth above should be reviewed on a regular basis.   Please note that any change in or deviation from the facts as presented will render this ruling inapplicable.

Should additional information be needed, please contact Senior Counsel Kent L. Brown, General Counsel’s Office, Post Office Box 475, Jefferson City, Missouri 65105-0475, phone (573) 751-0961.

Sincerely,

Trish Vincent