Ruling 89-149
Trademark/Licensing Agreement
According to the information presented in your letter, your client renders a service whereby he arranges licensing agreements for use of a trademark owned by a corporation. The licensing agreements for use of the trademark are between the corporation that owns the trademark and manufacturers.
Based on the above set of facts, the service your client performs that involves arranging licensing agreements for use of a trademark is not subject to sales and use tax.
LEGAL DIVISION
October 12, 1989