Streamlined Sales & Use Tax Sourcing Survey
For Mixed Transactions
August 2008
State
Tax
Services?
Major Services Taxed
Source Services
Source PTE
Source Mixed
Transactions
Special Sourcing
Rules
NV
KS
NO
YES
None
 Telecommunications services—KSA 793603(b), Renting hotel rooms—KSA 793603(g)
 Renting tangible personal property—KSA
79-3603(h)
 Dry cleaning—KSA 79-3603(i)
 Cable, community antennae and other
subscriber radio and television
services—KSA 79-3603(k)
 Installing or applying tangible personal
property (with exemption for “original
construction” of commercial or residential
structures and repair and remodeling of
residences)—KSA 79-3603(p)
 Repairing, servicing, altering or
maintaining tangible personal property—
KSA 79-3603(q)
Maintenance agreement contracts—KSA
79-3603(r)
 Modifying, altering, updating or
maintaining prewritten computer
software—KSA 79-3603(s)
 Telephone answering services—KSA 793603(t)
 Prepaid calling service and prepaid
wireless calling service—KSA 79-3603(u)
NA
Destination
NA
Destination, but the
only product
transferred
electronically that is
taxed is prewritten
computer software
NA
It is difficult to
respond this
question in the
abstract, but
generally, Kansas
would apply the
Section 310
sourcing hierarchy
to the transaction
and would attempt
to source the entire
transaction to one
location under that
hierarchy.
NA
NA
SD
YES
Almost all services
Destination
Destination
NA
KY
YES
Destination – where
received by the
purchaser
Destination. For
admissions, it is where
the event is held
rather than where
Destination
Destination
NA
KRS 139.200 (2) provides for taxes on
the following:
(a) The rental of any room or rooms,
lodgings, or accommodations furnished
Page 1 of 15
State
RI
Tax
Services?
NO
Major Services Taxed
Source Services
by any hotel, motel, inn, tourist camp,
tourist cabin, or any other place in which
rooms, lodgings, or accommodations are
regularly furnished to transients for a
consideration. The tax shall not apply to
rooms, lodgings, or accommodations
supplied for a continuous period of thirty
(30) days or more to a person;
(b) Sewer services;
(c) The sale of admissions except those
taxed under KRS 138.480;
(d) Prepaid calling service and prepaid
wireless calling service;
(e) Intrastate, interstate, and international
communications services as defined in
KRS 139.195, except the furnishing of
pay telephone service as defined in KRS
139.195;
(f) Ring tones as defined in KRS 139.195,
to a purchaser whose place of primary
use is in this state; and
(g) Distribution, transmission, or
transportation services for natural gas
that is for storage, use, or other
consumption in this state, excluding those
services furnished:
1. For natural gas that is classified as
residential use as provided in KRS
139.470(8); or
2. To a seller or reseller of natural gas.
tickets may be
delivered.
NA
Destination
Page 2 of 15
Source PTE
Do not tax them
Source Mixed
Transactions
Tangible personal
property picked up
or delivered in RI is
subject to tax.
Separately stated
services and PTE
are not subject to
tax.
Special Sourcing
Rules
NA
State
Tax
Services?
Major Services Taxed
Source Services
Source PTE
Source Mixed
Transactions
Special Sourcing
Rules
IN
YES
Intrastate telecommunications services,
water softening and conditioning
services, cable or satellite radio and
television services, and lawn care
applications.
Destination, except for
telecommunications
Destination
Destination
NA
NC
YES
Telecommunications and ancillary
services
Video programming service (cable, directto-home satellite, etc.),
Satellite digital audio radio service
Dry-cleaning service
Accommodation rentals
Destination, except for
telecommunications
Do not tax them
Destination
NA
PA
YES
Lobbying
Adjustment, collection and credit
reporting
Secretarial or editing
Disinfecting or pest control
Building maintenance or cleaning
Employment agency
Help supply
Lawn care
Self storage
Premium cable or premium video
programming
Telecommunications
Pre-paid mobile telecommunication
Repairing, altering, mending, pressing,
fitting, dyeing, laundering, dry cleaning or
cleaning of taxable personal property
Destination
Do not tax them,
except for canned
software - destination
Destination
NA
TX
YES
(1) amusement services;
(2) cable television services;
(3) personal services;
(4) motor vehicle parking and
storage services;
(5) the repair, remodeling,
maintenance, and restoration of tangible
personal property, except:
(A) aircraft;
Combination - most
services are origin
sourced (and sales
and rentals of tangible
personal property);
however, the services
listed are sourced as
follows:
Amusement Services -
Page 3 of 15
Intrastate sales of
items other than
the services listed
in item #2 are
origin sourced
based on the
location of the
seller’s place of
business.
Most mixed
transactions are
examined for the
essence of the
transaction to
determine which
sourcing method
should be used.
For example a
Generally No
State
Tax
Services?
Major Services Taxed
(B) a ship or other vessel,
other than:
(i) a taxable boat or motor
(ii) a sports fishing boat; or
(iii) any other vessel used for
pleasure;
(C) the repair,
maintenance, and restoration of a motor
vehicle; and
(D) the repair,
maintenance, creation, and restoration of
a computer program, including its
development and modification, not sold
by the person performing the repair,
maintenance, creation, or restoration
service;
(6) telecommunications services;
(7) credit reporting services;
(8) debt collection services;
(9) insurance services;
(10) information services;
(11) real property services;
(12) data processing services;
(13) real property repair and
remodeling;
(14) security services;
(15) telephone answering services;
(16) Internet access service; and
(17) a sale by a transmission and
distribution electrical utility.
Source Services
based on where the
performance or event
occurs.
Cable TV -based on
where the customer
receives the service.
Florists - based on the
location of the place of
business that takes the
order, regardless of
where the delivery is
made.
Landline
Telecommunications
Services - sold on a
call-by-call basis
based on the location
of the telephone or
other device from
which the call or other
transmission
originates.
Mobile
Telecommunications
Services - based on
the place of primary
use.
Natural Gas and
Electricity - based on
where the customer
receives the gas or
electricity.
Real Property Repair
and Remodeling based on the location
of the job site.
Waste Collection
Services - based on
where the waste is
collected.
Page 4 of 15
Source PTE
Source Mixed
Transactions
waste removal
service provider
may also rent or
lease containers.
Waste removal is
taxed based on
where the service
is provided but
rentals of tpp are
taxed based on
the lessor’s place
of business. In
this type of mixed
transaction we
regard the
essence of the
transaction as the
waste removal
service. The
rental of the
container is simply
a sale in
connection with
the service and it
is sourced the
same as the
service.
Sellers must
separately state
charges for mixed
transactions that
include destination
based services
and origin based
services.
Special Sourcing
Rules
State
Tax
Services?
Major Services Taxed
UT
YES
Repairing of tangible personal property
Cleaning of tangible personal property
Accommodations
Admissions
MA
YES
Telecommunications
MI
YES
Electricity
Telecommunications
VT
VA
NO
Generally
NO
NA
As set forth in 23VAC10-210-4040: 1)
services that are provided in connection
with the sale of tangible personal property;
for example, any services in connection
with the furnishing, preparing, or serving by
a person for a consideration of meals or
other tangible personal property; 2)
services that are sold in connection with the
fabrication of tangible personal property,
whether or not the customer furnishes,
either directly or indirectly, the materials
used in fabrication; and 4) any rooms,
lodgings, or accommodations furnished to
transients by any hotel, motel, inn, tourist
camp or cabin, camping grounds, club, or
any other similar place furnished for less
than 90 continuous days.
Source Services
Source PTE
Source Mixed
Transactions
Special Sourcing
Rules
Destination
Origin – if seller
receives order in
Utah
Destination – if seller
receives order
outside of Utah
All sourced as per
Section 210.1.
Election if sold
under a single
contract and in the
same transaction
and billed on same
billing statement
No
Generally, MA uses
the Goldberg v. Sweet
rules for sourcing
telecommunications
services. See 830
CMR 64H.1.6,
Destination,
Telecommunications
sourced to 314.
Only Prewritten
software sourced to
destination (place of
use). Jane’s note:
prewritten software
is TPP, not PTE
Prewritten software
only – destination
NA
NA
No
NA
Origin. Virginia
sources the sale of its
taxable services in the
same manner as
taxable tangible
personal property, that
is, sales are sourced
to the place of
business. For
determining the place
of business in Virginia
from which a sale is
made, “place of
business” means the
business location in
Virginia that first takes
the purchaser’s order,
either in person, by
purchase order or by
NA
Va. Code § 58.1609.5(1) provides an
exemption from the
retail sales and use
tax for services not
involving an
exchange of tangible
personal property
which provide
access to or use of
the Internet and any
other related
electronic
communication
service, including
software, data,
content and other
information services
delivered
Destination,
except for
telecommunication
s
NA
Origin. As with the
sale of tangible
personal property
and the sale of
services, mixed
transactions
including a
combination of
tangible personal
property, services,
and products
transferred
electronically
would all be
sourced to the
seller’s place of
business, as
defined above.
Page 5 of 15
NA
NA
State
WI
Tax
Services?
Major Services Taxed
YES
1. Lodging
2. Admissions to entertainment, athletic,
recreational or amusement facilities or
events
3. Telecommunications
4. Laundry, dry cleaning, pressing, and
dyeing with exceptions
5. Parking motor vehicles and aircraft and
storing and docking boats
6. Photographic
7. Repair, service, maintenance, painting,
cleaning, towing, alteration, fitting,
inspection, coating of tangible personal
property
8. Printing, producing, processing, and
fabricating tangible personal property
9. Cable TV, including installation
10.
Landscaping
11.
Telecommunications messaging
Source Services
Source PTE
letter or telephone,
regardless of the
location of the
merchandise or the
point of acceptance of
the order or shipment.
electronically via the
Internet. The Tax
Commissioner has
consistently held that
transactions
involving data
accessed online by
personal computers,
including
transactions
involving software
content delivered via
the Internet, are
nontaxable service
transactions
because they do not
involve the
exchange of tangible
personal property.
Generally destination
(where the serviced
property or property
resulting from the
service is delivered to
the purchaser). See
attachment at end of
survey for specific
examples.
The products
transferred
electronically that WI
currently imposes
tax on is software
(deemed to be
tangible personal
property) and
photographs with
photographic
services. Sourcing
is to destination.
Page 6 of 15
Source Mixed
Transactions
The transaction is
generally a sale of
a service or tpp
based on the true
objective of the
purchaser. Rarely
is it both.
However, if items
are distinct sales,
Wisconsin would
source based on
the rule for each
item.
Special Sourcing
Rules
No
State
Tax
Services?
Major Services Taxed
IA
YES
Major services are repair type services.
Also included are such services as:
barber and beauty; vehicle wash and
wax; and solid waste collection and
disposal services. Services are listed in
Iowa Code section 423.2(6).
AR
YES
The following are examples of taxable
services: wrecker and towing; collection
and disposal of solid waste; dry cleaning
and laundry; mini-warehouse and self
storage rental; pest control; and
telecommunications. Arkansas also taxes
the initial installation, alteration, addition,
cleaning, refinishing, replacement and
repair of several items including motor
vehicles, aircraft, electrical appliances and
devices, and machinery.
AL
YES
NE
YES
Source Services
Source PTE
Source Mixed
Transactions
Special Sourcing
Rules
Tax is due when the
service is rendered,
furnished, or
performed in the State
of Iowa or when the
results of the service
are used in the State
of Iowa. Iowa Code
section 423.1(50).
These sales are
sourced where the
products are
received. However
Iowa has an
exemption for
property that is
transferred digitally
or electronically,
Iowa Code section
423.3(67).
These sales are
sourced based on
destination. If the
service is
rendered,
furnished, or
performed in Iowa,
then the service
would be sourced
there first.
No
Destination
NA
Destination
NA
Services, such as installation labor, are not
taxable when separately stated; however,
labor or service charges are taxable if the
labor or service (i) is incidental to making,
producing, or fabricating a new or different
item or tangible personal property or
otherwise preparing the item for sale and
(ii) is performed prior to transfer of title to
the purchaser.
Stand alone services, separate and apart
from the sale of any tangible
personal property are not taxable.
If a service is
determined to be
taxable, as in number
1 above, it would be
sourced to/with the
TPP. Alabama is a
destination state.
Destination
If a service is
determined to be
taxable, as in
number 1 above, it
would be sourced
to/with the TPP.
Alabama is a
destination state.
NA
Nebraska taxes utilities, cable and satellite
service, admissions, fabrication labor,
building cleaning, pest control, security,
Destination – where
purchaser makes first
use of the service.
Nebraska currently
taxes only electronic
mailing lists. Sales
Page 7 of 15
See Previous
Answer
See Previous
Answer
State
Tax
Services?
Major Services Taxed
Source Services
motor vehicle washing, towing, and
painting, software training, installation of
TPP, repair of TPP – except motor vehicles
Source PTE
Source Mixed
Transactions
Special Sourcing
Rules
of such lists are
sourced to the
location where the
lists are received by
the purchaser.
Beginning October
1, 2008, Nebraska
will begin taxing the
specified digital
products. Sourcing
rules for the
specified digital
products are being
developed.
WA
YES
Construction; alteration, repair, decorating
or tangible personal property or real
property; amusement and recreation
businesses; credit bureau services; and,
title, abstract, and escrow services.
Washington follows
sections 310 and 311
of the SSUTA for the
sourcing of services.
Where the purchaser
makes first use of the
services is where the
purchaser receives the
service.
Washington follows
sections 310 and 311
of the SSUTA for the
sourcing of sales of
PTE. The PTE is
received by the
purchaser where
possession is taken
or first use is made,
whichever comes
first.
MO
YES
In general Missouri does not tax services
unless they are specifically enumerated in a
statute. Examples would be Hotels,
Electricity, and Restaurants.
A combination of both,
depending on the
service.
NA
Page 8 of 15
Washington
follows sections
310 and 311 of the
SSUTA for the
sourcing of all
transactions
except direct mail
and those items
allowed to be
excluded from
section 310
sourcing (motor
vehicles, etc.).
Missouri uses the
“true object test” to
determine this.
The true object
test decides the
real object the
buyer seeks in
making the
purchase. Is the
object the TPP or
the service? The
essentials of the
transaction
NA
Missouri does not
source based on
the seller
regardless if the
object is TPP only
or a combination of
TPP and a service.
The sourcing is
based on the
product.
State
Tax
Services?
Major Services Taxed
Source Services
Source PTE
Source Mixed
Transactions
Special Sourcing
Rules
determine the true
object.
ND
YES
North Dakota taxes very few services,
primarily communication services,
admissions to places of amusement, coinoperated amusement, and rental of hotel
and motel rooms.
Communication
services - based on
SST sourcing rules
Other services –
destination
Only prewritten
computer software destination
NA
NA
IL
NO
Illinois taxes only the tangible personal
property transferred incident to a sale of
service.
NA
Origin - Sell
prewritten computer
software only
NA
NA
NJ
YES
New Jersey is a
destination state,
historically. Since its
conformance to the
Streamlined
Agreement, New
Jersey law has been
amended to include the
provisions of Rule 310,
which defines “first
use” as in the
incidence of sourcing.
As most of the taxable
services in New Jersey
require some physical
presence to complete
performance, the “first
use” concept has not
modified the manner in
which most sales of
services are sourced.
New Jersey currently
taxes sales of digital
property, which
includes
electronically
delivered music,
ringtones, movies,
books, audio and
visual works and
similar products. To
date, New Jersey’s
exposure to these
transactions has
generally been
limited to sales made
to individual
purchasers, where
first use can be
determined as the
place of delivery (i.e.personal home
computer, cell phone,
etc.). New Jersey
anticipates the
difficulties stressed
above as these
transactions expand
to multi-state
New Jersey imposes sales tax on the
receipts from retail sales of the following
services: Producing, fabricating,
processing, installing, maintaining, repairing,
storing, and servicing tangible personal
property; maintaining and repairing real
property, direct-mail advertising processing
services in connection with advertising or
promotional material; storage of tangible
personal property; telecommunications
services charged to a New Jersey address;
utility service (natural gas, electricity)
provided to customers in New Jersey; some
personal services, such as tanning,
massage and tattooing, investigation and
security services and information services.
However, services that
are performed via
electronic media have
proven difficult to
determine the place of
“first use”. For
Page 9 of 15
As tangible
personal property
and digital goods
are both sourced
under Rule 310,
New Jersey would
approach the
sourcing of a mixed
transaction in the
same manner that
it would a nonmixed transaction.
As stated above,
New Jersey has
amended its law to
include the
provisions of Rule
310 to determine
sourcing for
tangible personal
property, which
includes digital
property under New
Jersey law, and
services.
State
Tax
Services?
Major Services Taxed
Source Services
example, information
can be received via
online access on the
seller’s server,
transferred to the
actual user directly or
delivered to the actual
user’s server that may
be accessed by
multiple users from
many locations. From
an audit perspective,
retracing the
transaction proves
burdensome.
TN
YES
1) Sales, rental or charges for rooms,
lodging, or accommodations to the same
person for less than 90 continuous days…
2) Charges for parking services rendered
by a parking garage, parking lot or other
place for purpose of parking or storing
motor vehicles…
3) Furnishing intrastate, interstate and
international telecommunication services
4) Performing of any repair services with
respect to any kind of tangible personal
property
5) Laundering or dry cleaning of any kind of
tangible personal property except coinoperated laundry, dry cleaning or car wash
facilities…
6) Installing tangible personal property that
remains tangible personal property after
installation
7) Enriching of uranium materials,
compounds, or products
8) Renting or providing of space to a dealer
or vendor without a permanent location in
this state or to persons who are registered
1) Telecommunication
services are sourced
according to Tenn. Code
Ann. § 67-6-905 which is
the SST
telecommunications
sourcing pursuant to
SSUTA Sections 314
and 315.
2) Ancillary services
are sourced according
to Tenn. Code Ann. §
67-6-905(c) which is
the SST sourcing for
ancillary services in
SSUTA Section 314.
3) Other services –
Origin – Sales and
Use Tax Rules &
Regulations 1320-5-2.05 provides, sales
are sourced to the
place of business
within the physical
Page 10 of 15
Source PTE
Source Mixed
Transactions
Special Sourcing
Rules
business purchases.
Tennessee does not
impose tax on all
products transferred
electronically.
Effective January 1,
2009, (a) the retail
sale, lease, licensing
or use of specified
digital products
transferred to, or
accessed by
subscribers or
consumers in this
state are subject to
sales and use tax.
(g) The tax imposed
by this section shall
apply to retail sales
in this state,
indicated by the
residential street
address or the
primary business
street address of the
The mixed
transactions are all
basically sourced
the same. They
are sourced to the
place of business
within the physical
limits of a local
government from
which sales are
made. See
Response to #2.
NA
State
Tax
Services?
Major Services Taxed
for sales tax at other locations in this state
but who are making sales at this location on
a less than permanent…
9) Furnishing ancillary services
10) Fees for subscription to, access to, or
use of television programming services
provided by video programming service
provider (cable, wireless cable and wireline)
11) Fees for subscription to, access to, or
use of television programming by a provider
of direct-to-home satellite services
12) Sales of warranty or services contracts
covering the repair or maintenance of
tangible personal property or computer
software
13) Sales of non-prewritten computer
software (custom)
Source Services
limits of a local
government imposing
the local tax where
delivery is made by the
dealer to a place within
the physical limits of
the state. The place
where a user or
consumer may take or
use tangible personal
property or taxable
service has no bearing
on whether a sales tax
is due. A dealer
making sales from a
place of business
within the physical
limits of a local
government imposing
a local sales tax shall
not be liable for any
sales tax where he
delivers possession of
the tangible personal
property or taxable
services… (Note:
Tennessee sales tax
applies to taxable
services performed in
this state on tangible
personal property that
is shipped or delivered
out of state.)
4) Warranty or
maintenance contracts
are subject to
Tennessee sales tax
when:
a) The contract is sold
as a part of the sale of
the tangible personal
Page 11 of 15
Source PTE
subscriber of
consumer. Effective
January 1, 2009 until
July 1, 2009, local
tax with respect to
specified digital
products that are
subject to state tax
shall be imposed at
the rate of two and
one-half percent
(2.5%). Public
Chapter 1106
Sections 19 and 21
(2008).
Tennessee does
impose sales and
use tax on the retail
sale, lease or
licensing of both
prewritten computer
software and nonprewritten computer
software whether
delivered on tangible
storage media,
delivered
electronically, load
and leave or some
other means.
Source Mixed
Transactions
Special Sourcing
Rules
State
Tax
Services?
Major Services Taxed
Source Services
Source PTE
Source Mixed
Transactions
Special Sourcing
Rules
We would
determine
sourcing based on
the true object of
the transaction.
For example, a
transaction that
involved the
provision of plants
and the setting
No. For example,
a landscaping
company that also
runs a plant store
would source the
landscaping
services to the
customer location
(destination) and
sales of tangible
property covered by
the contract and the
underlying sale of the
tangible personal
property is subject to
Tennessee sales tax.
b) Both the buyer and
seller of the contract
are located in
Tennessee, without
regard to where the
tangible personal
property is located or
where the parties may
contemplate the work
covered by the
contract will be done.
c) At the time when the
buyer and seller enter
into the contract, the
tangible personal
property that the
contract covers is in
Tennessee, or will be
located in Tennessee,
or, in the case of
mobile property, will be
based in Tennessee
during the term of the
contract.
OH
YES
a. Repair of tangible personal property,
b. Installation of tangible personal property,
c. Laundry and dry cleaning services,
d. Washing, cleaning, polishing, or painting
motor vehicles,
e. Automatic data processing, computer
services and electronic information
services,
f. Telecommunications service,
g. Landscaping and lawn care service,
Under current law, we
source different
services differently.
Of the list above,
services listed as e, g,
h, i, j, k, l, o, and s are
sourced the location of
the consumer where
the service is
Page 12 of 15
NA
State
MN
27
Tax
Services?
YES
Major Services Taxed
h. Private investigation and security
service,
i. Building maintenance and janitorial
service,
j. Employment Service,
k. Employment placement service,
l. Exterminating service,
m. Physical fitness facility memberships,
n. Recreationand sport club memberships,
o. Satellite broadcasting service,
p. Personal care service (including skin
care, manicuring and pedicuring,tattooing,
body piercing,tanning and massage),
q. Intrastate transportation of persons by
motor vehicle or aircraft,
r. Motor vehicle towing service,
s. Snow removal service, and
t. Storage of tangible personal property.
 Admissions to places of amusement,
recreation, or athletic events and
charges for access to amusement
devices, tanning facilities, reducing
salons, steam baths, turkish baths,
health clubs, and spas and athletic
facilities
 Lodging services
 Nonresidential parking services, except
meters
 Memberships to organizations the
provide sports or athletic facilities for
members
 Delivery of aggregate materials and
concrete block by a third party
 Laundry and dry cleaning services
including cleaning, pressing, repairing,
altering, and storing clothes, linens
services and supply, cleaning and
blocking hats, carpet and drapery,
upholstery, and industrial cleaning.
Excludes coin operated laundry and dry
Source Services
Source PTE
performed or received
(essentially
destination).
Telecommunications
service has its own
rule consistent with the
SSUTA section 314.
Other services are
sourced to the
vendor’s place of
business (essentially
origin).
Minnesota has
adopted the
General Sourcing
Rules in Section
310, General
Sourcing
Definitions in
Section 311, Direct
Mail Sourcing in
Section 313,
Telecommunicatio
n and Related
Services Sourcing
Rules in Section
314 and the
Telecommunicatio
n Sourcing
Definitions in
Section 315 of the
SSUTA. Services
are sourced based
on those rules
generally to
Page 13 of 15
Minnesota has
adopted the
General Sourcing
Rules in Section
310, General
Sourcing
Definitions in
Section 311,
Direct Mail
Sourcing in
Section 313,
Telecommunicati
on and Related
Services
Sourcing Rules in
Section 314 and
the
Telecommunicati
on Sourcing
Definitions in
Section 315 of
the SSUTA.
Services are
Source Mixed
Transactions
Special Sourcing
Rules
and planting of
those same plants
at the customer’s
location would be
considered a
landscaping
service and
sourced to the
customer’s
location
(destination).
personal property
by the store to the
origin.
We have not
addressed this
issue in
Minnesota. In
most situations
we have
reviewed, the
sale of the
service and the
sale of the
tangible
personal
property are
separately
stated on the
invoice. For
example, the
purchase of a
cell phone is
separately
priced from
wireless
telecommunicat
NA
State
Tax
Services?
Major Services Taxed














cleaning services.
Motor vehicle washing, waxing, and
cleaning services, including coin
operated facilities, and rustproofing,
undercoating, and towing of motor
vehicles
Building cleaning and maintenance,
disinfecting and exterminating services
and pest control
Detective, security, burglar, fire alarm,
and armored car services
Pet grooming services
Lawn care, fertilizing, mowing, spraying
and sprigging services
Garden planting and maintenance, and
indoor plant care
Tree, bush, and shrub pruning, bracing,
spraying, surgery, stump removal and
tree trimming for public utility lines
Massage services, except when
provided by or under a written referral
from a licensed health care facility or
professional
Lodging, board and care services for
animals, excluding veterinary and horse
boarding services.
Telecommunications services.
Ancillary services associated with
telecommunications services
Cable television and direct satellite
services
Ring tones
Installation charges by a third party if the
installation would be taxable if provided
by the seller of the item being installed
Source Services
destination or to
the primary place
of use.
Page 14 of 15
Source PTE
sourced based
on those rules
generally to
destination or to
the primary place
of use.
Source Mixed
Transactions
ions services.
The tangible
personal
property is
sourced under
the general
sourcing rules
to the location
where the
customer
receives the
cell phone and
the wireless
services are
sourced to the
customer’s
place of
primary use
under the
telecommunicat
ions sourcing
rules. Although
we have no
official position
on this, if there
was no
separation in
cost between
the cell phone
and the cell
phone service,
we would likely
look at the true
object of the
transaction and
source based
on that. In this
scenario, the
true object of
the transaction
is the wireless
Special Sourcing
Rules
State
Tax
Services?
Major Services Taxed
Source Services
Source PTE
Source Mixed
Transactions
telecommunicat
ions services
and so the
transaction
would be
sourced to the
customer’s
place of
primary use
under the
telecommunicat
ions sourcing
provisions.
Page 15 of 15
Special Sourcing
Rules