Is Texas sales tax due on foot reflexology services provided at a reflexology shop?

Plain-English summary

A shop owner asked the Comptroller's office whether the foot reflexology services provided at their shop were subject to Texas sales tax. The shop described its service as a technique for stimulating nerve endings in the feet to relieve tension and renew vitality, based on the idea that reflex points in the feet correspond to organs throughout the body.

The Comptroller responded that if the provider is licensed as a physical therapist or massage therapist, the provider is not required to collect tax on these services. The letter pointed the taxpayer to Comptroller Rule 3.317 for further reference. The letter does not address what tax treatment applies if the provider is not so licensed.

What this means for you

Reflexology and massage service providers

If you or your business provides foot reflexology services and you hold a license as a physical therapist or massage therapist, this letter indicates you are not required to collect Texas sales tax on those services. Providers who are not licensed in one of these capacities should consult Comptroller Rule 3.317 and current guidance, since this letter does not resolve that scenario.

Business owners and accountants

Because this ruling turns entirely on the provider's professional licensing status, keep documentation of relevant licenses on file to support the tax treatment applied to reflexology or similar bodywork services.

Tax professionals

This letter is a narrow, facts-specific response from 1995 and references Rule 3.317, which governs the taxability of personal services including massage therapy. Confirm the current text of Rule 3.317 and any subsequent STAR guidance before relying on this letter for a present-day engagement.

Common questions

Q: Is foot reflexology a taxable service in Texas?
A: Under this letter, if the person providing the reflexology service is licensed as a physical or massage therapist, tax is not required to be collected on the service.

Q: What happens if the reflexology provider is not a licensed physical or massage therapist?
A: This letter does not address that situation; it only states the outcome for licensed physical or massage therapists.

Q: What rule governs this determination?
A: The letter refers the taxpayer to Comptroller Rule 3.317.

Citations and references

No specific statutes are cited in the text of this letter; the letter refers the taxpayer to Comptroller Rule 3.317 without quoting it.

Source

• STAR search: https://star.comptroller.texas.gov/search?doc_type_code=L&tax_type_code=SST
• Opinion: https://star.comptroller.texas.gov/view/9501L1331C09

Original ruling text

January 12, 1995

Dear **:

I have received your letter regarding the taxability of the services you
provide.

Facts: You state that your shop provides foot reflexology, a technique to
stimulate nerve endings in the feet to relieve tension and renew vitality.
Reflexology is a science dealing with the principle that there are reflexes
in the feet related to each and every organ in all parts of the body.

Question: You ask if this is a taxable service.

Response: If you are licensed as a physical or massage therapist, then
you would not be required to collect tax on these services. Enclosed is a
copy of Rule 3.317 for your reference.

This opinion is based on the facts presented. If there are additional or
different facts, the opinion could change.

You may call me toll free at 1-800-531-5441, Ext. 3-4663. My direct line
is 512/463-4663. You may also write to Tax Administration Division,
Comptroller of Public Accounts.

Sincerely,

Joan Hale
Tax Administration Division

NOTE: Previous Accession Number 9501858L