Ruling 89-154

Engineering

The reconstruction of motor vehicle accidents by a licensed professional civil engineer is exempt from sales and use tax pursuant to section 12-412(11) of the Connecticut General Statutes. The civil engineer is the final consumer of all materials, e.g., reimbursable expenses and photographs used in providing his services. The civil engineer must pay the sales and use tax for purchases of taxable materials and supplies used in rendering his services and he is not permitted to issue resale certificates to suppliers for said materials and sup- plies. The total gross receipts for purchases of reimbursable expenses by civil engineers or business consultants are subject to sales and use tax when the service providers are performing services for governmental agencies.

A real estate management company located in Connecticut or out of state must apply the sales and use tax to the gross receipts for managing a shopping center in Connecticut. A Connecticut real estate management company would not apply Connecticut sales and use tax for management services rendered to a shopping center located outside Connecticut provided the sole benefit and use of the services inure outside this state.

Services rendered by a Connecticut service provider to an out-of-state client are not subject to Connecticut sales and use tax provided the sole benefit and use of the services inure outside Connecticut.

LEGAL DIVISION

October 23, 1989