Does South Carolina's 5% admissions tax apply to charges to enter or use my venue — a gym, golf course, escape room, bowling alley, movie theater, museum, or similar place of amusement?

Plain-English summary

South Carolina imposes a 5% admissions tax (a "license tax") on paid admissions to a place of amusement. In Revenue Ruling #26-2 the Department updates its long-running guidance on what counts as a place of amusement and gives an extensive — but explicitly not all-inclusive — list of taxable venues and a list of charges it treats as non-taxable.

Two statutory points do most of the work. First, the tax applies to the paid right or privilege to enter into or use a place [§ 12-21-2410]. The South Carolina Supreme Court confirmed the "use" branch in Beach v. Livingston (1966), holding that charges to use a bowling alley were taxable even though there was no separate charge just to walk in. Second, the statute never defines "amusement," so the Department applies its longstanding test: any enclosure or location with an activity that "occupies one's spare time, distracts the mind, relaxes, entertains, or gives pleasure." A place can serve a business or other purpose and still be a place of amusement.

Under that test the ruling lists dozens of taxable venues — amusement parks, bowling alleys, health clubs, golf courses and country clubs, escape rooms, movie theaters, museums, spas, skating rinks, pickleball and tennis courts, shooting ranges, water parks, ziplines, and more. It also lists charges the Department does not tax, such as lessons from an instructor, tournament participant entry fees (apart from the normal green/court fees), touring boat/carriage/helicopter/plane/bus rides, one-time (nonrecurring) club initiation fees, and — under a 2024 statutory change — monthly or annual dues paid to a golf club.

What this means for you

Venue, event, and attraction operators

If you charge the public to get into or use your location — whether it's a traditional entertainment venue or a facility that also has a business purpose — assume the 5% admissions tax applies unless you can point to a specific exemption in § 12-21-2420 or § 12-21-2430. The ruling's list is illustrative, not a limit: newer formats like escape rooms, ax throwing, selfie museums, inflatable waterparks, and paint-splatter events are all called out as taxable. The burden of proving an exemption is on the operator, and while an exemption application isn't legally required, the Department recommends obtaining an exemption certificate (Form L-2068, now filed through MyDORWAY) before the event if you believe you qualify.

Golf, tennis, and health/athletic clubs

Club charges split several ways. Green fees, driving-range fees, court fees, pool fees, and general membership dues are taxable. But since May 13, 2024, monthly or annual dues paid specifically to a golf club are exempt [§ 12-21-2420(17)] — an exemption that does not extend to clubs without golf, nor to green fees, driving-range fees, or optional fees. Separately, a one-time, nonrecurring initiation fee (a true prerequisite to joining, not a substitute for recurring dues) is not taxed, and lessons from an instructor (golf, tennis, dance, self-defense, equestrian, etc.) are not admissions. Note some club charges shift to a different tax: golf-cart and boat/jet-ski rental fees are subject to sales tax rather than admissions tax.

Accountants and tax professionals

The decisive questions are (1) is there a paid charge to enter or use a place, and (2) does the activity fall within the Department's broad "amusement" definition. Because the definition is deliberately not strictly construed, a dual-purpose location (e.g., a museum, botanical garden, or historical attraction) is usually taxable, subject to narrow statutory carve-outs (the State Museum under § 12-21-2420(16); certain historical-site and cruise exemptions that do not reach concerts or entertainment cruises). RR #26-2 supersedes RR #05-14 and pulls together prior authority including RR #89-8, #91-14, #24-4, #25-8, #09-12, and #92-1, PLR #13-4, and TAM #94-1 and #95-2 — check those where a specific charge is close to the line.

Common questions

Q: Is my gym or fitness studio subject to the admissions tax?
A: Generally yes — health clubs are listed as places of amusement, so membership and use fees are taxable. RR #26-2 flags SC Revenue Ruling #92-1 for a discussion of when a health club may be exempt, so review that if you think you qualify.

Q: We run an escape room / ax-throwing / laser-tag venue. Are we taxable?
A: Yes. All three are on the Department's taxable list. The tax reaches the charge to use the facility, so it applies even if there's no separate "entry" fee.

Q: Are golf-club dues taxable?
A: Monthly or annual dues paid to a golf club are exempt as of May 13, 2024. But green fees, driving-range fees, optional fees (like a hole-in-one prize fee), and dues at a club that doesn't offer golf remain taxable.

Q: What common charges are NOT admissions?
A: Instructor lessons, tournament participant entry fees (beyond the ordinary green/court fees), touring or charter boat/carriage/helicopter/plane/bus rides, and one-time nonrecurring initiation fees. Golf-cart and boat/jet-ski rentals are taxed as sales, not admissions.

Q: Can I rely on this ruling for my business?
A: It's the Department's stated position for the general category of taxpayers it addresses, and it applies to all periods open under the statute — but it's an advisory opinion, not a taxpayer-specific ruling, and it can change if the law or the Department's position changes. Your specific facts and any applicable exemption should be confirmed.

Citations and references

Statutes:

• S.C. Code Ann. § 12-21-2420 (2014) — imposes the 5% admissions license tax; statutory exemptions (incl. (16) State Museum, (17) golf-club dues)
• S.C. Code Ann. § 12-21-2410 (2014) — defines "admission," "place," and "person"
• S.C. Code Ann. § 12-21-2430 (2014) — additional admissions-tax exemptions

Case law:

• Beach v. Livingston, 248 S.C. 135, 149 S.E.2d 328 (1966) — admissions tax reaches paid "use" of a place, not just entry

Related SC advisory opinions (described in prose, not linked): RR #05-14 (superseded by this ruling), RR #89-8, RR #91-14, RR #24-4, RR #25-8, RR #09-12, RR #92-1, PLR #13-4, TAM #94-1, TAM #95-2.

Source

• Landing page: SC Advisory Opinion Search
• Original PDF: RR26-2.pdf

Original ruling text

STATE OF SOUTH CAROLINA

DEPARTMENT OF REVENUE
300A Outlet Pointe Blvd., Columbia, South Carolina 29210
P.O. Box 125, Columbia, South Carolina 29214-0575

SC REVENUE RULING #26-2
SUBJECT:

Places of Amusement
(Admissions Tax)

EFFECTIVE DATE:

Applies to all periods open under the statute.

SUPERSEDES:

SC Revenue Ruling #05-14 and all previous advisory opinions and any
oral directives in conflict herewith.

REFERENCES:

S. C. Code Ann. Section 12-21-2420 (2014)
S. C. Code Ann. Section 12-21-2410 (2014)
S. C. Code Ann. Section 12-21-2430 (2014)

AUTHORITY:

S.C. Code Ann. Section 12-4-320 (2014)
S.C. Code Ann. Section 1-23-10(4) (2005)
SC Revenue Procedure #09-3

SCOPE:

The purpose of a Revenue Ruling is to provide guidance to the public. It
is an advisory opinion issued to apply principles of tax law to a set of
facts or general category of taxpayers. It is the Department’s position
until superseded or modified by a change in statute, regulation, court
decision, or another Department advisory opinion.

INTRODUCTION:
The State of South Carolina imposes an admissions tax for the privilege of entering and using a
place of amusement. The purpose of this advisory opinion is to update the Department’s guidance
regarding examples of places of amusements that are subject to this tax. The list of examples is
not all-inclusive and is being provided as guidance for taxpayers.

LAW AND DISCUSSION:
Code Section 12-21-2420 imposes the admissions tax and states in part:
There must be levied, assessed, collected, and paid upon paid admissions to places
of amusement within this State a license tax of five percent. The license tax may
be listed separately from the cost of admission on an admission ticket.

Code Section 12-21-2410 defines the terms “admissions,” “place,” and “person” for purposes of
the admissions tax and states:
(1) The word “admission” means the right or privilege to enter into or use a place
or location;
(2) The word “place” means any definite enclosure or location; and
(3) The word “person” means individual, partnership, corporation, association, or
organization of any kind whatsoever.
In summary, the admissions tax is imposed upon the paid right or privilege to enter into or use a
place of amusement.
It is important to note that the statute taxes charges to "use" a place of amusement, as well as
charges to “enter into” a place of amusement. See Beach v. Livingston, 248 S.C. 135, 149 S.E.2d
328 (1966) (South Carolina Supreme Court held that the admissions tax applied to paid charges
for the "use" of a bowling alley even though there was no charge for a person to “enter” the bowling
alley).
The statute, however, does not define the term “amusement.” The Department’s longstanding
position as to what constitutes an “amusement,” and as such a “place of amusement” for purposes
of the admissions tax, is “any enclosure or location consisting of an activity that occupies one’s
spare time, distracts the mind, relaxes, entertains, or gives pleasure.” See SC Revenue Rulings

89-8 and #91-14; SC Private Letter Ruling #13-4. Furthermore, “the term ‘place of amusement’

is not to be strictly construed so as to exclude places which may also have a business or other
purpose. If a place distracts the mind, relaxes, entertains, or gives pleasure, then such place is a
‘place of amusement.’” SC Revenue Ruling #89-8.

Examples of Places of Amusements Subject to the Admissions Tax
The following list of places of amusements is not all inclusive and is merely provided as guidance.
Charges to enter or use these places, events, facilities and rides and all other amusement facilities
are subject to the tax unless specifically exempted under Code Section 12-21-2420 or Code
Section 12-21-2430:
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Air shows
Amusement parks
Amusement rides, shows and exhibits
Animal shows
ATV, UTV, and dirt bike riding parks
Aquariums
Aquatic shows
Archery ranges
Art and craft exhibitions (SC Revenue Ruling #89-8)
Automobile shows

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Ax throwing
Balloon shows
Banana boat rides
Baseball batting cages (SC Revenue Ruling #91-14)
Basketball courts
Boat cruises (See, however, Code Section 12-21-2420(13). Charges for cruises with
entertainment, such as ones with bands, audience role participation (i.e., patrons attempt
to solve a murder mystery), or plays, do not come within the exemption in Code Section
12-21-2420(13).)
Botanical gardens
Bowling alleys
Bungee jumping
Carnival, circus and fair entrance fees, rides, shows, exhibits, games, and other
amusement charges
College, professional and other sporting events (football, basketball, baseball, or hockey
games; golf tournaments; tennis tournaments; rodeos; car races; polo matches; horse
races; wrestling matches; boxing matches; etc.)
Comedy clubs
Dance halls
Dance shows
Dinner theaters and attractions (See SC Revenue Ruling #25-8)
Dog shows
Escape rooms
Fishing piers and ponds
Flight and similar simulators
Flyboarding
Food and/or drink festivals
Go cart or car racing tracks to include “pit passes” 1
Golf courses and country clubs 2
Golf driving ranges
Handball courts
Health clubs (See, however, SC Revenue Ruling 92-1 for a discussion of exempt health
clubs.)
Historical attractions (See, however, Code Section 12-21-2420(9). Note: Charges for
entertainment events, such as rock concerts, on the grounds of a location on the National
Register of Historical Places do not come within the exemption in Code Section 12-212420(9))

“Pit passes” may be exempt under Code Section 12-21-2420(15).

As of May 13, 2024, any monthly or annual dues paid to a golf club are exempt from admissions
tax. This exemption does not apply to monthly or annual memberships paid to a club that does not
offer golf. Nor does this exemption apply to green fees, driving range fees, or optional fees, such
as an optional fee to win cash prizes for making a hole-in-one in a specific hole. Code Section 1221-2420(17), S.C. Rev. Rul. #24-4 and S.C. Technical Advice Memo. #94-1.

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Holiday celebrations and events (Halloween haunted houses, New Year Eve parties,
firework shows, crop circles and mazes, etc.)
Historical dramas
Home tours (new homes, historical homes, Christmas tours, etc.)
Horse shows
Inflatable waterparks or obstacle courses
Indoor playgrounds
Laser tag
Mazes, including crop mazes
Miniature golf or putt-putt courses
Miniature or slot car tracks
“Monster” truck shows
Motorcycle expositions, races and shows
Movie theaters
Museums 3
Music concerts
Nightclubs, lounges, or bars with a cover charge
Pageants
Paint ball or laser gun facilities
Paint splatter events
Para sail rides
Parade of Homes tours
Pickleball courts
Planetariums
Plays
Promotional events such as boat shows, home shows, antique shows, gun and knife
shows, and wildlife expositions and shows (See SC Revenue Ruling #89-8)
Race car or similar tracks (reality racing, ATV tracks, etc.)
Racquetball courts
Rock climbing facilities
Rodeos
Ropes courses
Selfie museums
Serpentariums
Skating rinks or skateboard parks
Shooting ranges (target, skeet, trap sporting clays, etc.)
Smash events
Spas
Spectator events (football, basketball, baseball, or hockey games; golf tournaments;
tennis tournaments; rodeos; car races; polo matches; horse races; wrestling matches;
boxing matches; etc.)

Charges for admission into the State Museum are exempt from admissions taxes. S.C. Code Ann.
§ 12-21-2420(16).

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Sport clubs
Squash courts
Stage plays or performances
Swimming pools and clubs (pool fees, membership dues—unless the membership dues
are monthly to annual dues paid to a golf club (see footnote 2))
Target, skeet, trap or sporting clay ranges
Theaters
Tractor pulls
Tennis or racquetball courts (court fees, membership dues—unless the membership dues
are monthly or annual dues paid to a golf club (see footnote 2))
Video game lounges
Water parks
Water-skiing shows
Water slides
Wildlife preserves
Ziplines
Zoos

It should be noted that it has been the Department’s longstanding position that the following
charges are not subject to admissions tax:
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Fees for golf, tennis, baseball, softball, dancing, or self-defense lessons from an instructor
Tournament participant entry fees (exclusive of the normal and customary charges to
utilize the place of amusement, i.e. green or court fees) (SC Revenue Ruling #09-12)
Fees for boat, carriage, helicopter, plane or bus rides for touring, charter, fishing, or
excursion (SC Technical Advice Memorandum #95-2)
Golf cart fees (subject to sales tax as rentals)
“Trail fees” (fees charged by golf courses for someone using their own golf cart)
Boat or jet ski rental fees (subject to sales tax)
Fees for using tanning beds
Initiation fees for country clubs, golf clubs, tennis clubs and similar facilities 4 provided the
initiation fee is a one-time (nonrecurring) charge paid as a prerequisite to joining the club
Fees for equestrian lessons are not fees to enter or use a place of amusement and are not
subject to the admissions tax

Note: Organizations, event organizers, and others operating places of amusement should
review Code Sections 12-21-2420 and 12-21-2430 to determine if their organization, location,
or event falls within one of the statutory exemptions. The burden of proof that an
organization, location, or event falls within an exemption rests with the operator of the place
of amusement.

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An initiation fee should not allow a person to utilize the facilities of the club without payment of
a recurring charge (membership dues). In other words, a one-time charge that is a substitute for
recurring membership dues is not an initiation fee.

An application for exemption is not required by law; however, it is recommended that an
organization, event organizer, or others operating places of amusement apply for and obtain
an exemption certificate prior to the event if they believe their organization, location, or
event falls within one of the statutory exemptions. The instructions on how to apply an
exemption certificate are in Form L-2068 (Application for Admissions Tax Exemption).
The Department no longer accepts paper copies of the Application for Admissions Tax
Exemption (Form L-2068). All Admissions Tax exemption requests must be submitted
through the Department’s free online tax portal, MyDORWAY, at MyDORWAY.dor.sc.gov.
If you do not already manage your Admissions Tax account on MyDORWAY, you must sign
up for a MyDORWAY account to request Admissions Tax exemptions.
SOUTH CAROLINA DEPARTMENT OF REVENUE

s/W. Hartley Powell
W. Hartley Powell, Director
January 20
,2026
Columbia, South Carolina