Are pet pedicures (nail trims) performed by a veterinarian and staff exempt from New York sales tax as veterinary medicine, or are they taxable grooming?

Plain-English summary

Clark Animal Care Center performs pedicures (nail trims) on pets, arguing this is preventive medicine: overgrown nails can catch in carpeting or decking and tear off painfully, sometimes requiring surgery to stop bleeding or fix the resulting injury. The practice compared this to vaccinating pets to prevent disease and asked whether its pedicure charges are exempt as veterinary medicine.

New York generally taxes services that maintain or service tangible personal property, but exempts services that are the actual practice of veterinary medicine — defined by the Education Law as diagnosing, treating, operating, or prescribing for an animal's disease, pain, injury, deformity, or physical condition. The exemption explicitly does not extend to other services a veterinarian might provide, including boarding, grooming, and clipping, even when performed by a licensed veterinarian. The Department's own regulations list "grooming" and "clipping" of pets as examples of taxable nonprofessional services.

The Department found that a pedicure is a grooming/clipping service, not the diagnosis or treatment of a disease, pain, injury, or physical condition — regardless of the preventive-health rationale offered. So Clark Animal Care Center's pedicure charges are subject to New York State and local sales tax, even though performed by licensed veterinarians and staff.

What this means for you

Veterinary practices offering grooming-adjacent services

The veterinary exemption is narrower than "anything a vet does for a health reason" — it's tied specifically to the legal definition of practicing veterinary medicine (diagnosis, treatment, and similar functions), not to whether a service has some preventive health benefit. Routine grooming services like nail trims, clipping, bathing, and boarding are taxable even when performed in-house by licensed veterinary staff and even when framed as preventive care.

Accountants serving veterinary clients

Watch this exemption boundary carefully on client invoices: charges genuinely for diagnosing or treating disease, injury, or physical conditions are exempt, but adjacent services like grooming, clipping, and boarding are taxable and should be billed and taxed separately if bundled with exempt treatment.

Common questions

Q: Is everything a veterinarian does exempt from sales tax?
A: No. Only services that constitute the actual practice of veterinary medicine (diagnosing, treating, or prescribing for disease, pain, injury, or physical conditions) are exempt. Grooming, clipping, and boarding are specifically taxable even when performed by the same veterinarian.

Q: Does it matter that the pedicure prevents future injury or health problems?
A: No. The Department's analysis focused on what category of service a pedicure is (grooming/clipping), not on whether it has a preventive health rationale.

Q: Can another veterinary practice rely on this ruling?
A: No. This advisory opinion binds the Department only for Clark Animal Care Center LLP on the facts described, though it reflects the Department's general regulatory position (20 NYCRR § 528.24) that grooming and clipping are taxable regardless of provider.

Citations and references

Statutes and regulations:

• Tax Law § 1105(c)(3) (tax on maintaining, servicing, or repairing tangible personal property)
• Tax Law § 1115(f) (veterinary medicine exemption)
• 20 NYCRR § 528.24 (veterinary exemption; taxable boarding, grooming, and clipping)

Source

• Landing page: https://www.tax.ny.gov/pubs_and_bulls/advisory_opinions/sales_ao_2001.htm
• Opinion: https://www.tax.ny.gov/pdf/advisory_opinions/sales/a01_11s.pdf

Original ruling text

New York State Department of Taxation and Finance

Office of Tax Policy Analysis
Technical Services Division

TSB-A-01(11)S
Sales Tax
April 12, 2001

STATE OF NEW YORK
COMMISSIONER OF TAXATION AND FINANCE
ADVISORY OPINION

PETITION NO. S001019A

On October 19, 2000, the Department of Taxation and Finance received a Petition for
Advisory Opinion from Clark Animal Care Center LLP, 1672 Fairport Nine Mile Pt. Rd, Penfield,
NY 14526.
The issue raised by Petitioner, Clark Animal Care Center LLP, is whether pedicures
performed by veterinarians and their professional staff are subject to State and local sales and use
taxes.
Petitioner submits the following facts as the basis for this Advisory Opinion.
Petitioner performs pedicures on animals to prevent future health problems. Overgrown
nails may become entrapped in carpeting and wood decking and consequently tear off near their
origin where the nail grows from bone. Having a nail torn off is very painful to an animal and
sometimes surgery is then necessary to stop hemorrhaging or correct ensuing health problems.
Petitioner states that providing a nail trimming service for pets is akin to vaccinating pets to prevent
disease, and as such is part of preventative medicine.
Applicable Law and Regulations
Section 1105(c)(3) of the Tax Law provides, in part, for the imposition of sales tax on
maintaining and servicing tangible personal property.
Section 1115(f) of the Tax Law provides, in part:
Services rendered by a veterinarian licensed and registered as required by the
education law which constitute the practice of veterinary medicine as defined in said
law, including hospitalization for which no separate boarding charge is made, shall
not be subject to tax under paragraph (3) of subdivision (c) of section eleven hundred
five, but the exemption allowed by this subdivision shall not apply to other services
provided by a veterinarian to pets and other animals, including, but not limited to,
boarding, grooming and clipping. . . .
Section 528.24 of the Sales and Use Tax Regulations provides, in part:

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TSB-A-01(11)S
Sales Tax
April 12, 2001

(a) Exemption. (1) The exemption is allowed for services rendered by a
licensed veterinarian which constitute the practice of veterinary medicine, including
hospitalization for which no separate boarding charge is made.
(2) The exemption is not applicable to other services provided by a
veterinarian, including but not limited to boarding, grooming and clipping.
(3) The exemption is allowed for articles of tangible personal property
designed for use in some manner relating to domestic animals or poultry, when sold
by such a licensed veterinarian.
(b) Definitions. (1) Practice of veterinary medicine. Section 6701 of the
Education Law defines the practice of the profession of veterinary medicine as
diagnosing, treating, operating or prescribing for any animal disease, pain, injury,
deformity or physical condition. Animal includes every living creature except human
beings.
(2) Use of title veterinarian. Section 6702 of the Education Law provides that
only a person licensed or exempt under article 135 of the Education Law shall
practice veterinary medicine or use the title veterinarian.
*

*

*

(d) Taxable transactions. (1) Nonprofessional services performed by a
veterinarian are subject to tax.
Example 1: Boarding, clipping and washing of pets are services which are
subject to tax.
Opinion
Petitioner performs pedicures on animals to prevent future health problems. Section 1115(f)
of the Tax Law provides an exemption from sales tax for services rendered by a veterinarian which
constitute the practice of veterinary medicine. The provisions of Section 1115(f) indicate
that for purposes of such section the service of grooming or clipping pets is not a service which
constitutes the practice of veterinary medicine. The service of providing pedicures is considered
grooming or clipping, which is taxable under Sections 1105(c)(3) and 1115(f) of the Tax Law. See
Section 528.24 of the Sales and Use Tax Regulations. Accordingly, pursuant to Sections 1105(c)(3)

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Sales Tax
April 12, 2001

and 1115(f) of the Tax Law pedicures performed by Petitioner are subject to State and local sales
taxes.

DATED: April 12, 2001

NOTE:

/s/
Jonathan Pessen
Tax Regulation Specialist III
Technical Services Division

The opinions expressed in Advisory Opinions are
limited to the facts set forth therein.