Is labor to clean and detail a private corporate aircraft taxable, and does it matter if the cleaning includes steam-cleaning the carpet?

Plain-English summary

A newly started sole-proprietorship business cleaning and detailing corporate aircraft asked the Comptroller to confirm, in writing, that a state representative's earlier phone guidance was correct: no tax on general cleaning labor, but a tax specifically for steam-cleaning carpets. The Comptroller confirmed both points:

• No tax is due on labor charges for maintenance-type cleaning of a private aircraft — general cleaning/detailing labor is nontaxable.
• Carpet cleaning, however, is its own separately taxable service under Tex. Tax Code § 151.0045 and 34 Tex. Admin. Code Rule 3.310 — so if the business steam-cleans carpets (even inside an aircraft it's otherwise cleaning nontaxably), that specific service is taxable.
• Regardless of whether the labor itself is taxed, the business must pay tax on the supplies, materials, and equipment it buys to perform its (nontaxable) cleaning service — except that it can issue a resale certificate for products that are physically transferred to the customer, like carpet deodorizer, and collect tax on those instead of paying it upfront.

What this means for you

Aircraft, boat, and vehicle detailing/cleaning businesses

General cleaning and detailing labor for private aircraft (and by the same logic, vehicles and boats) is not taxable. But watch for carpet cleaning specifically — it's carved out as its own taxable service under § 151.0045/Rule 3.310, so if your service menu includes steam-cleaning carpets, tax that portion of the charge even while the rest of your detailing labor stays exempt.

Cleaning businesses generally

You're the taxable consumer of most supplies and equipment you use to perform nontaxable cleaning services — pay tax when you buy them. The one carve-out is products that pass through to the customer's property (like a carpet deodorizer left behind): for those, you can use a resale certificate and instead collect tax from the customer.

Accountants and tax professionals

This letter is a useful confirmation that carpet cleaning is treated as a distinct taxable service line under § 151.0045/Rule 3.310, separable from an otherwise-nontaxable general cleaning/detailing labor charge — relevant any time a service provider's menu mixes taxable and nontaxable cleaning tasks.

Common questions

Q: Is labor to clean a private corporate aircraft taxable?
A: General cleaning/detailing labor is not taxable.

Q: What about steam-cleaning the carpet inside the aircraft?
A: That's taxable — carpet cleaning is its own taxable service under Tex. Tax Code § 151.0045 and Rule 3.310, regardless of the nontaxable status of the surrounding general cleaning work.

Q: Do I pay tax on my cleaning supplies and equipment?
A: Generally yes, since you're providing a nontaxable service — but you can use a resale certificate for products that are physically transferred to the customer (like carpet deodorizer) and collect tax on those instead.

Q: Can I rely on this letter for my own cleaning business?
A: No. This opinion is based on the facts submitted, and other facts, though similar, may result in different answers.

Citations and references

Statutes and rules:

• Tex. Tax Code § 151.0045 (taxable services — carpet cleaning)
• 34 Tex. Admin. Code Rule 3.310 (taxable services)

Source

• STAR search: https://star.comptroller.texas.gov/search?doc_type_code=L&tax_type_code=SST
• Opinion: https://star.comptroller.texas.gov/view/200004220L

Original ruling text

April 19, 2000

Dear **:

Thank you for your recent letter concerning the taxability of cleaning
corporate aircraft.

Information Provided: My husband recently started a business cleaning and
detailing corporate aircraft. It is a sole proprietorship. I spoke with a
representative at the State Comptrollers Office in ** regarding
state tax on labor. He explained to me that there is no tax on this type of
service but did go on to say that there is a tax for steam cleaning the
carpets. Although at this time, we do not offer that particular service. He
suggested that I request something in writing to verify this information is
correct. Could you please send me something confirming our conversation as soon
as possible?

Response: Tax is not due on labor charges for maintenance such as cleaning of
private aircraft. You should pay tax on all supplies, materials and equipment
used to provide the nontaxable service.

Carpet cleaning is a taxable service under Texas Tax Code Sec. 151.0045 and
Rule 3.310. You may issue a resale certificate in lieu of products such as
carpet deodorizer that is transferred to the customer.

The State Tax Automated Research (STAR) system, which provides viewing and
downloading of our rules, the Tax code, edited letter rulings, hearings,
Attorney General Opinions, etc., may be accessed on the Internet at:
http://www.window.state.tx.us/

This opinion is based on the facts you submitted and current law. Other facts
though similar, may result in different answers. If you have any questions or
need more information, I'll be glad to help you. Please call me toll free at
1.800.531.5441, extension 5.0330. My direct line is 512.475.00330. My email
address is .

Sincerely,

Bettie Peterson
Tax Policy Division